Anti-Money Laundering and Counter Terrorism

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Anti-Money Laundering and Counter Terrorism Financing

SinoPac Holdings  has established the "Anti-Money Laundering and Counter Terrorism Financing Policy" ("AML/CFT Policy") for compliance by SinoPac Holdings and all subsidiaries. The subsidiaries also established their own internal regulations and operating procedures for anti-money laundering and counter terrorism financing based on laws for their respective industries, related industrial laws and regulations, the self-disciplinary regulations and conventions of industry associations, and references provided in the AML/CFT Policy of SinoPac Holdings.

Anti-Money Laundering Management Framework

To implement the Group's anti-money laundering and countering the financing of terrorism (AML/CFT) tasks and create an AML/CFT culture, SinoPac Holdings established the "Risk Management Committee" under the management of the Chairman of SinoPac Holdings. The Chairman of SinoPac Holdings serves as the chair of the Committee and supervises and manages the AML/CFT risk and the integration and distribution of resources between subsidiaries. The Legal & Compliance Division of SinoPac Holdings serves as the dedicated AML/CFT unit responsible for supervising and assisting the planning and execution of AML/CFT operations of subsidiaries. SinoPac Holdings established the Guidelines for Information Sharing and established an information sharing platform to prevent omissions in horizontal communication between subsidiaries from causing gaps in AML operations. Under the premises of ensuring the protection of personal information and ensuring information confidentiality, SinoPac Holdings requires all subsidiaries to share their money laundering or terrorism financing patterns and blacklists on a regular or irregular basis. The information should be uploaded to SinoPac Holdings' information sharing platform for reference by all subsidiaries.

Bank SinoPac established the Anti-Money Laundering Committee which is chaired by the President. The Committee is responsible for the management and coordination of the operations of different units in the Bank. Bank SinoPac also established the Anti-Money Laundering Center to take charge of the planning and supervision of related AML/CFT systems of the Bank and supervise the branches in the implementation of AML operations. Dedicated AML/CFT supervisors or personnel have been assigned in other subsidiaries including SinoPac Securities, SinoPac Futures, SinoPac Securities Investment Trust, and SinoPac Leasing to take charge of related AML/CFT affairs.

Assessment Mechanisms and Results 

SinoPac Holdings requires its subsidiaries to adopt a consistent methodology for the annual institutional risk assessment (IRA). As an example, Bank SinoPac and SinoPac Securities appointed external consultants to help introduce the IRA methodology, designed assessment questionnaires for the four major risk factors, and used evaluation mechanisms to calculate inherent risks and control measures in order to evaluate residual risks. Bank SinoPac followed the regulations of the competent authority and appointed an external accountant to provide an assurance report on the design and execution of the AML/CFT internal control system.

Customer Due Diligence

To implement anti-money laundering and counter terrorism financing tasks, Bank SinoPac has established a detailed Customer Due Diligence (CDD) process, which also included non-face-to-face CDD procedures for customers with opening online or digital accounts, as well as background checks and identity verification procedures for politically exposed persons (PEPs).