FAB Financial Crime Compliance Program

FAB Group is committed to uphold the highest standards in combatting money laundering and terrorism financing, in accordance with UAE laws and regulations, and the Financial Action Task Force (FATF) recommendations and international best practices. As a global financial institution, FAB has a critical role in protecting and safeguarding the financial system and hence, it has adopted a zero tolerance approach to non-compliance with the laws and regulations of the jurisdictions in which it operates.

FAB Group has established a global Anti-Money Laundering (AML)-Counter Terrorist Financing (CTF) program to protect both its clients and affiliates from the risks of money laundering and terrorism financing. The foundation of this program is FAB’s AML-CTF Policy, which provides the minimum set of standards to be adhered across the Group and to also ensure Compliance with the applicable local regulatory requirements where it operates.

The program includes but is not limited to:

• Appointment of a Group and Country Money Laundering Reporting Officer (MLRO) as required by local regulation.
• Establishing comprehensive governance and oversight of the program across the bank.
• Undertaking Customer Due Diligence (CDD) measures, which covers customer Identification and Verification (“ID&V”), Know Your Customer (“KYC”), customer risk rating and screening.
• Identification and screening of all customers, including higher risk customers such as Politically Exposed Persons (“PEPs”), their relatives and close associates.
• Undertaking AML transaction monitoring to identify and report suspicious activities.
• Maintenance of robust systems and technology.
• Providing ongoing mandatory AML and CTF training to all staff.
• Ensuring that an independent function regularly tests the effectiveness and adequacy of internal policies, procedures, systems and controls associated with combating potential ML/TF crimes.
• Maintenance of all records, documents and data relating to customers and transactions as required by the local regulation.
• The prohibition of the following products, services and customer types:
  • Shell entities / banks;
  • Anonymous or numbered accounts or customers seeking to establish a relationship in obviously fictitious names or pseudonyms;
  • Payable-through-accounts through local or foreign banks customers;
  • Money Service Bureau or similar type of organisations, Charities, Non-governmental Organisations (NGOs), Non-profit Organisations (NPOs) and any other organisations that are not legally established in the country or permitted by local laws, including foreign charities; and
  • Virtual banks that offers banking services through electronic channels, Crypto/Virtual currency products.

The Wolfsberg Group Financial Crime Compliance Questionnaire (FCCQ) is a shorter version of the CBDDQ and contains a basic set of questions to address industry demand. Download the FAB Wolfsberg Group Financial Crime Compliance Questionnaire.

First Abu Dhabi Bank (FAB) Group is obliged to comply with the directives of the Regulatory Authorities of the State. Also FAB Group, as an international bank, is committed to complying with international sanctions laws and regulations, by virtue of its presence or participation in international trade and financial transactions.

FAB Group Sanctions Policy defines key principles, which all FAB Group affiliates must comply with, including:

• Screening customers and transactions against global sanctions lists issued by the United Nations Security Council (UNSC), the European Union (EU), the United Kingdom (HMT) and the United States (OFAC), as well as against relevant local lists that apply to FAB’s operations in a particular jurisdiction.
• Prohibiting business activity which includes on-boarding or continuing customer relationships or providing products or services or facilitating transactions that FAB believes may violate applicable sanctions or FAB’s Group Sanctions Policy. This includes prohibitions on business activity with individuals or entities named in a sanctions list or activity, directly or indirectly, involving countries or territories subject to comprehensive sanctions. These countries include Cuba, Iran, North Korea, Syria, and the Crimea region of Ukraine.
• Customer Screening: Screening all customers and applicable connected parties for sanctioned targets, in accordance with applicable sanctions regimes.
• Transaction Screening: The Group conducts real-time transaction screening on all transactions in relation to relevant lists of designated persons, groups and entities subject to financial sanctions.
• Reserving the right on its sole discretion, not to process transaction(s), or provide products or services even though it is permitted under applicable sanctions laws or are covered under general or specific licenses from the applicable sanctioning authority, where these activities fall outside of FAB’s risk appetite.
• Blocking or rejecting transactions where FAB is required to do so under applicable sanctions laws or FAB Group Sanctions Policy.
• Reporting of Sanctions breaches to the relevant Regulatory Authorities.

FAB Group is committed to conducting the business in accordance with the highest ethical standards and in full compliance with all applicable anti-bribery and corruption laws and regulations including but not limited to; Foreign Corrupt Practices Act (FCPA), UK Bribery Act, UAE laws and other applicable local country laws / regulations where FAB operates.

FAB Group AB&C Policy applies to all activities and operations across the Group, irrespective of their jurisdictions, businesses and operations including second- and third-party employees and is binding for all Group branches, affiliates and subsidiaries except where the provisions of the Policy differ due to the local regulatory requirements (the more stricter requirements will take precedence).

FAB Group has zero-tolerance towards bribery and corruption and prohibits them in any form, both directly and indirectly.

Key components of FAB Group AB&C Program include:

• Oversight, governance and escalation
• Risk assessment process Communication and training
• Review and pre-approval processes
• Due diligence on third party relationships
• Confidential reporting, financial controls and record-keeping
• Independent testing processes

FAB’s AB&C Program also encompasses the following overarching key principles:

FAB strictly prohibits any form of bribery (payment, offer or promise to pay or provide anything of value), gifts and hospitality, facilitation payments and payments to government to secure or expedite the performance of a routine action or otherwise induce public officials or third parties to perform routine functions they are otherwise obliged to perform in order to secure an improper advantage.

It is strictly prohibited to interact with a public official, including their representatives or agents, with the intention of influencing actions taken within their official function or securing any such improper advantages.

Employment opportunities, whether permanent or temporary in nature, and internships (whether paid or unpaid) must be merit-based, fair and in line with the hiring standards applied for all employees, and must not be used as an inducement to anyone to act improperly for obtaining or retaining an advantage in business.

Associated persons and third parties engaged to represent FAB’s interests must comply with the principles set out in the FAB Group AB&C Policy. FAB mandates appropriate level of due diligence on all such associated persons and third parties, and the application of suitable contractual terms and governance to reduce bribery and corruption risks.