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(PP) AeA) le od SL! sanque Algérienne Talacker 41 / Postfach, 8021 Zurich ‘winw.bace.ch du Commerce Extérieur S.A. Telefon: +41 44 218 50 60 info@bace.ch Algerische Aussenhandelsbank AG Telefax: +41 44 211 36 27 ‘Swift: AEXTCHZZ To whom it may concern Zurich, 15 Mars 2017 Anti Money Laundering and Combatting the Financing of Terrorism Declaration, Policy and Activities Declaration Banque Algérienne du Commerce Extérieur SA (BACE), is a prosperous Swiss bank under the law of Switzerland and located in Zurich, Switzerland. Switzerland is a member country of the Financial Action Task Force on Money Laundering (FATF). The bank is regulated by the Swiss Financial Market Supervisory Authority “FINMA’ and is subject to the provisions relating to due diligence, money laundering and combating the financing of terrorism, in particular: 1, Swiss Criminal Code (Art. 260 ter, Art. 260 quinquies, Art. 305 bis and Art. 305 ter), 2. Federal Act on Combating Money Laundering and Terrorist Financing in the Financial Sector of 10 October 1997 (Status as on 4 .lanuary 2016), 3. Federal Ordinance of 11 November 2015 on Combating Money Laundering and Terrorist Financing in the Financial Sector, 4. FINMA Ordinance (AMLO-FINMA) of 3 June 2015 on Combating Money Laundering and Terrorist Financing in the Financial Sector, 5. SBA Agreement on the Swiss banks’ Code of Conduct with regards the Exercise of due diligence (CDB 16) of 01 June 2015, entry into force on 01 January 2016, 6. Circular of the Swiss Financial Market Supervisory Authority “FINMA" concerning Market conduct rules of 29 August 2013 entry into force 01 October 2013. The above are incorporated in the BACE’s internal directives and standard procedures. Policy Anti-Money Laundering (AML) and Combating the Financing of Terrorism (CFT) principals are enforced by the Risk Management & Compliance Department, which reports directly to the Comité de Direction (Executive board). The Risk Management & Compliance Department integrates AML laws, professional laws and ethical rules in internal directives, procedures and rules which are implemented in the bank. The Risk Management & Compliance Department in AML & CFT is based on the following principals: > Implementation of a Compliance culture within the bank > Implementation and control of the respect of KYC, KYP and KYT principals, > Identification of clients, determination of beneficial owners and monitoring of suspicious transactions, > Identification, monitoring and management of compliance and reputational risks > Co-ordination and supervision of procedures at bank level, > Prohibition of + Entering into relationships with criminal and terrorists organizations, ‘+ Accepting proceeds of corruption or such related crimes, ‘+ Maintaining relationships with shell banks BACE SA pursues a strict intransigent policy with the purpose to maintain and constantly improve a high standard in Compliance and Due diligence. Activities Anti Money laundering and Combatting the Financing of Terrorism activities, that the Risk Management & Compliance Department executes, can be summarized as follows: - Ensuring compliance with the standards and internal directives against money laundering in force, - Identification customers, collect information regarding their business activities and update information relating to high risk client information in line with CDB 16, - Identification the beneficial owners of the customers, > Establish a record for each new customer identification documents and ‘Know Your Customer’ information. Name matching between relationship participant and verification against international black lists. - Identification transactions, screening and monitoring suspicious transactions and payments and PEP’s, - Regular relationship risk assessment, - Management board approval for high risk relationships, - Annual review of risk policies and risk assessment of the bank activities. Yearly review by management board, - Board of directors approval of the Risk Management & Compliance Department activities plan, - AML training programs for employees and communications about changes to existing laws or news, - Regular reporting to the Management Board and annual reporting to the Board of directors, - Reporting ta the Maney | aundering Reporting Office Switzerland (MROS) and the ‘Swiss Financial Market Supervisory Authority “FINMA’ regarding suspicious activities For further AML inquiries please contact the following: 1. Mr Abdallah Sellam Head Risk Management & Compliance E.mail: a.sellam@bace.ch Tel: +41 44218 5062 2. Mr Christoph Lathy Chief Operating Officer (COO) E.mail : c.lathy@bace.ch Tel +41 442185060 Yours sincerely, Banque Algérienne du Commerce Extérieur SA C.Lothy o A. Sellam coo Head Risk Management & Compliance