JSC FINCA Bank’s Statement on AML and CFT Policies

JSC FINCA Bank Georgia is an affiliate of FINCA Impact Finance Global Network that is headquartered in Washington, DC, United States. JSC FINCA Bank Georgia is regulated by several regulatory agencies: National Bank of Georgia, Financial Monitoring Service of Georgia. Bank’s AML Program is based on the following domestic legislation that includes: Law of Georgia “On Facilitating of Prevention of Legalization of Illicit Income”; Decree #4 of Financial Monitoring Service of Georgia “On Approving the Regulation on Receiving, Systemizing and Processing the Information by Commercial Banks and Forwarding to the Financial Monitoring Service of Georgia”, as well as on international rules and regulations, such as EU 4th Directive, US PATRIOT ACT. Bank’s AML Group activities are based on international best practices and recommendations of international regulatory bodies, such as FATF, Basel Committee on Banking Supervision. JSC FINCA Bank Georgia makes every effort to remain in full compliance with all applicable anti-money laundering laws, rules and standards.

As required by law, JSC FINCA Bank Georgia has established independent monitoring and control unit – AML Group, to oversee JSC FINCA Bank’s anti-money laundering efforts. The AML Group is under Risk Management and Compliance Department, which reports directly to the CEO. JSC FINCA Bank Georgia has developed and implemented a risk-based AML program comprising written anti-money laundering policy approved by Management and Supervisory Board, procedures, internal controls and systems, which include but are not limited to the following: a Know Your Customer Program (including the requirement to establish the identity of Ultimate Beneficial Owners and identification procedures of Politically Exposed Persons); processes to assess AML related risks; procedures to monitor customer transactions and activities; procedures to identify and report suspicious activities; processes to keep required records; and processes to conduct AML Trainings for appropriate employees in applicable aspects of financial crimes laws, rules and regulations, as well as the Bank’s AML requirements and money laundering prevention.

FINCA Bank Georgia constantly invests in technological advancements to improve the ongoing AML monitoring and controlling processes.

Regular reviews of the effectiveness of the internal AML/CFT Policy are carried out, in addition to audits periodically undertaken by the Internal Audit function of FINCA Bank Georgia. Bank cooperates fully with regulatory investigations and inquiries. JSC FINCA Bank Georgia does not do business with “shell banks.”

JSC FINCA Bank Georgia’s Management Board is fully committed to financial inclusion and recognizes that prevention of money laundering and terrorist financing is critically important. Thus, JSC FINCA Bank’s Management Board is fully committed and uses its best efforts to protect the financial institution from misuse of the Bank’s products and services and to prevent overall abuse of the financial system.

Mr. Vusal Verdiyev

Chief Executive Officer

FINCA Bank Georgia JSC

JSC FINCA Bank Georgia US PATRIOT Act Certification