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Money laundering prevention

Anti-money laundering and terrorism financing requires entities to set effective rules and procedures in order to carry out financial operations in accordance with current regulations, the most advanced international standards and the related recommendations issued by the Financial Action Task Force (FATF).
In Spain, Law 10/2010 of 28 April 2010 on anti-money laundering and the related implementing regulations set out the obligations that obliged subjects must meet depending on their corporate purposes and activity.
In Bankinter Group, money laundering and terrorism financing prevention represents a strategic objective and an ethical commitment to society as a whole and to the fulfilment of related control standards. Therefore, it has created a control framework which sets out its anti-money laundering and terrorism financing policies as well as how to comply with the international financial sanction programmes, control procedures and the corporate governance framework found in the Anti-money laundering and terrorism financing policies and procedures manual.
For the purpose of this control framework, the terms below are defined as follows:
Money laundering
The participation in any activity that aims to acquire, possess, use, convert, transfer, conceal or disguise the nature, origin, location, disposition, movements or the actual ownership of assets or rights over these, knowing that they proceed from a criminal act or participation in a criminal act.
Terrorism financing
The supply, deposit, distribution or collection of funds, by any means, directly or indirectly with the intention that they be used entirely or in part to commit a crime of terrorism.
International financial sanctions
Political, economic and diplomatic instruments used by countries and international institutions have influence upon the containment of terrorism, the defence of human rights, armed conflicts and the control over the development of weapons of mass destruction.

Main aspects and control framework of the anti-money laundering and terrorism financing policy

The core components of the anti-money laundering and terrorism financing system in Bankinter Group are:
Risk assessment and management. Regular reviews of the risk profile and the ML/TF risk exposure of operations.
Internal policymaking and procedures to comply strictly with all legal requirements relating to anti-money laundering and terrorism financing.
Customer segmentation and identification and Know-Your-Customer. Customers are classified in terms of risk in order to take proportionally diligent measures and monitor high-risk customers and high AML/TF-risk transactions as necessary.
Customer bans: Customers who fail to disclose required information in compliance with current regulations or who are included in any of the following banned customer categories will not be approved:
  • - Persons found on any of the official list of sanctions and criminal activity in general.
  • - Persons who cannot properly identify themselves or prove the legitimacy of their activity or the origin of their funds.
  • - Persons who decline to provide required information and documentation.
  • - Legal entities with ownership or control structures and/or an actual ownership that  cannot be determined.
  • - Financial entities in countries and territories where they are not physically present (shell banks).
  • - Money remitters, bureaux de change or gambling entities without official authorisation.
  • - Bitcoin trading companies
  • - Others included on the banned customer list that are part of the customer approval policy foud in the AML/FT Procedures Manual.
Mandatory customer authorisation prior to approval from the internal anti-money laundering and terrorism financing control board or from any designated special bodies or units for this purpose. Customers requiring such authorisation include:
  • - Politically exposed persons (PEPs), or persons who hold or have held public office as defined in current legislation, as well as their family members or close relations both domestically or internationally.
  • - Customers involved in the production or distribution of weapons, explosives and other similar products.
  • - Casinos or betting companies duly authorised.
  • - Money remitters, bureaux de change, money transfer companies and other similar entities.
  • - Other.
Remote identification. Formal policies in place on customer identification through remote channels, in accordance with the requirements provided in current legislation.
Activity analysis and monitoring. A control framework in place to monitor business relationships continuously with all types of customers, with particular emphasis on sensitive or high AML/FT-risk transactions; and, therefore, detect and, if necessary, analyse and report suspicious activity.
Suspicious activity reporting and systematic transaction reporting. Performance of reporting duties required under current regulations and cooperation with the competent authorities.
Policy on financial sanctions. There are efficient policies and procedures to comply effectively with all restrictions defined in sanctions programmes and international financial countermeasures.
Correspondent banks. Efficient policies and procedures to take diligence measures and monitor business relationships continuously.
Record-keeping. A sound registry of customer documentation and completed transactions, for a period of 10 years, in accordance with current regulations.
AML/TF training. The bank has an annual AML/FT training programme for all employees and the entire agent network. It provides specialised training for certain control areas and areas that manage customers with higher-than-average risk.
The bank's internal organisation is based on a three lines-of-defence model with defined functions and duties in order to comply with the anti-money laundering and terrorism financing control framework. This organisational structure has:
First line of defence. Business and support units are the first line of defence and are charged with identifying, assessing and controlling business risks. Their functions include enforcing anti-money laundering and terrorism financing policies and procedures.
Second line of defence. The Regulatory Compliance Division (AML/FT) is in charge of enforcing the anti-money laundering and terrorism financing policies and procedures adopted by the bank through the centralised control and monitoring framework.
Third line of defence. The internal audit function regularly carries out independent assessments of control policies and procedures and the effective management of the anti-money laundering and terrorism financing system.
The Internal Control Board (ICB) is the AML/TF risk governance body, responsible for anti-money laundering and terrorism financing policymaking, monitoring and control in the Group. The Internal Control Board is made up of senior executives in the bank who represent the various business and control areas in the Group at the highest level. The Internal Control Board regularly reports to the audit and regulatory compliance committee of the board of directors of Bankinter.
Prevention of Money Laundering and Monetary Offences (SEPBLAC). The anti-money laundering area reports regularly on its operations to Bankinter's Internal Control Board.
For any matter relating to the content of this page or the anti-money laundering function, please sent an email to: Prevencion_de_Blanqueo@bankinter.com
For further information, please refer to the company information. You may also consult the notes to Bankinter Group's financial statements.
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