Financial Crime Compliance

Financial Crime Prevention Statement

At Evocabank, we are fully committed to combatting all forms of financial crime, including but not limited to money laundering, terrorist financing, fraud, bribery, corruption, sanction. As a responsible financial institution, we recognize our role in the global fight against financial crime, and we take proactive measures to protect the integrity of our financial system and the trust of our customers.

We have established a comprehensive approach to financial crime prevention, which includes the following key elements:

1. Know Your Customer (KYC) & Customer Due Diligence (CDD)

We adhere to stringent Know Your Customer (KYC) and Customer Due Diligence (CDD) practices to ensure that we are fully aware of our customers' identities, business activities, and risk profiles. This includes:

• Collecting and verifying personal and business information from all customers, including source of funds and nature of business.
• Assessing the risk level of each customer, using a risk-based approach that considers factors such as geographical location, the customer's business model, and transaction patterns.
• Conducting Enhanced Due Diligence (EDD) for high-risk customers, including Politically Exposed Persons (PEPs), customers from high-risk jurisdictions, or customers with complex ownership structures.

2. Anti-Money Laundering (AML) Measures

We are committed to complying with all applicable anti-money laundering (AML) laws, regulations, the Republic of Armenia Central Bank directives, and international best practices. Our AML measures include:

• Identification of unusual transactions or suspicious activity.
• The use of advanced technology and data analytics tools to detect and investigate patterns indicative of money laundering activities.
• Maintaining comprehensive records of all customer transactions and monitoring for signs of potential money laundering or terrorist financing.
• Reporting suspicious activities to relevant authorities promptly.

3. Combating the Financing of Terrorism (CFT)

We strictly adhere to all regulations related to combating the financing of terrorism (CFT). This includes:

• Ensuring that no services or products are offered to individuals or entities linked to terrorist organizations or activities.
• Conducting periodic screenings of customers against international terrorist watchlists, including the UN Sanctions List and other relevant authorities.
• Employing a risk-based approach to monitor transactions and detect potential financing of terrorism activities.

4. Sanctions Evasion

Evocabank is committed to full compliance with all applicable sanctions regulations, including those enforced by the

• United Nations Security Council
• S. Department of the Treasury’s Office of Foreign Assets Control (OFAC)
• S. Department of Commerce’s Bureau of Industry and Security
• European Union Council
• United Kingdom’s His Majesty’s Treasury

This includes:

• Screening all customers, transactions, and business relationships against the above-mentioned sanctions lists, to identify individuals, entities, and countries subject to sanctions.
• Rejection or termination of business relations with customers subject to sanctions or sanction affiliation.
• Prohibiting and preventing the facilitation of transactions or services that may involve sanctions evasion, and ensuring that no transactions are conducted with individuals or entities that are subject to sanctions.
• Regularly updating our systems to reflect the latest changes to sanctions lists and ensuring real-time screening of all transactions.
• Conducting enhanced due diligence and transaction reviews for high-risk countries, entities, or individuals known to be at risk of sanctions evasion.

5. Fraud Prevention

To protect our customers from fraud, we implement a range of proactive measures, such as:

• Real-Time Fraud Monitoring: Our systems track transaction data in real-time, looking for patterns indicative of fraud. When suspicious behavior is detected, transactions are either flagged or temporarily blocked for review.
• Customer Education: We proactively educate customers about common fraud tactics, such as phishing and identity theft, and provide guidelines on how to spot and report suspicious activity.
• Multi-Factor Authentication (MFA): We require customers to verify their identity through multiple channels (e.g., email, SMS, or biometric recognition) before granting access to their accounts or completing sensitive actions.
• 3D Secure Technology: We have integrated 3D Secure technology for online payments, adding an extra layer of authentication. This ensures that customers must verify their identity during the payment process, reducing the likelihood of unauthorized transactions.

6. Training & Awareness

We ensure that all employees receive ongoing training on financial crime prevention, including:

• Regular updates on current trends, typologies, and emerging risks in financial crime.
• In-depth training on the legal and regulatory requirements surrounding AML, CFT, and financial crime prevention.
• Encouraging staff to recognize and report suspicious activities or transactions.

7. Internal Controls & Risk Management

We have implemented a robust framework of internal controls to minimize the risk of financial crime:

• Timely and comprehensive reporting to Management and Supervisory Board on financial crime compliance matters.
• Regular audits and assessments to ensure compliance with internal policies and regulatory requirements.
• A zero-tolerance policy towards financial crime, with clear guidelines for reporting, investigating, and mitigating risks.

8. Collaboration with Regulatory Authorities

We maintain strong relationships with national regulatory bodies, law enforcement agencies to stay ahead of evolving threats. Our cooperation includes:

• Sharing information and intelligence regarding financial crime risks and suspicious activity with regulatory bodies and authorities as required by law.
• Responding promptly to information requests from law enforcement and regulatory agencies in accordance with legal requirements.

9. Compliance with Global Standards

We are committed to upholding global standards in the fight against financial crime. This includes complying with:

• The Financial Action Task Force (FATF) recommendations and guidelines.
• Local and international anti-money laundering and counter-terrorist financing regulations.
• Industry best practices set by organizations such as the Wolfsberg Group

10. Customer Responsibility

We encourage our customers to remain vigilant and report any suspicious activity, unauthorized transactions, or potential fraud. All alerts received by our customers are considered threats of high priority and are escalated to our fraud prevention and investigation team for examination.

If you suspect any fraudulent or suspicious activity related to your account, please feel free to contact us via [email protected] email address. We are here to assist you and ensure the security of your financial transactions.

Contact Us

For any inquiries regarding Evocabank's financial crime compliance, please reach out to us at [email protected].

At Evocabank, we believe that preventing financial crime is essential to maintaining the trust and confidence of our customers and the broader financial system. We are committed to continually improving our policies, systems, and training to meet the challenges of a rapidly evolving financial landscape.

Below you can find Evocabank FCC related documents:

• Financial Crime Compliance policy
• Wolfsberg questionnaire