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Anti-Money Laundering Acknowledgement and Global Certification Regarding Correspondent Accounts for Helaba Dublin Landesbank Hessen-Thüringen International
We, Helaba Dublin Landesbank Hessen-Thüringen International, are able to confirm herewith that our bank has the means and the internal procedures in place to detect and to intercept money laundering channels or chains involving the proceeds of terrorist activities, organized crime or others.
Helaba Dublin Landesbank Hessen-Thueringen International in Ireland is authorized and regulated by the Irish Financial Services Regulator Authority (Financial Regulator).
Following the "40 Recommendations" of the "Financial Action Task Force on Money Laundering", an intergovernmental body for the development and promotion of policies to combat money laundering, and the Directive 91/308/EWG (amended by Directive 2001/97/EG) of the Council of the European Community on the prevention of the use of the financial systems for the purpose of money laundering, the Irish Criminal Justice Act (the Act) came into force in June of 1994.
The Act has been amended repeatedly and the statutory duties resulting therefrom have been clarified by the Financial Regulator by means of issuance of respective guidelines (these guidelines is available on the Internet )
( Link to Financial Regulator Website)
Both the Act and the guidelines of the Financial Regulator oblige credit and financial service institutions to implement internal rules and safeguards with the aim of preventing money laundering. It is an integral part of Helaba Dublin's business policy to comply with those obligations here in Ireland.
Accordingly we have appointed a Money Laundering Reporting Officer and Deputy, who are responsible for the enforcement of the Act and the administrative provisions issued by the Financial Regulator for implementing it.
For this purpose, the Money Laundering Reporting Officer has created internal operating procedures for employees to include the duties to be complied with, which take the Act and the internal principles into account.
In particular, regular staff training dealing with money laundering methods and the catalog of obligations defined in the Criminal Justice Act as well as an annual reliability examination of staff is ensured.
In addition, we carry out checks (using probative official documents) on the true identity of our customers. Whenever we are obliged to identify a customer, we also establish the economic beneficiary, i.e. the person on whose behalf a transaction is carried out or who is involved in the transaction as a trustor. In the event of doubt as to whether the person to be identified is acting on his/her own behalf, or where it is certain that he/she is not acting on his/her behalf, we take reasonable measures to obtain information as to the real identity of the person on whose behalf the customer is acting.
Both our Internal Audit Division at Head Office and our external auditors perform annual audits to establish whether the security measures taken at Helaba Dublin to combat money laundering are reasonable and appropriate and whether the Money Laundering Reporting Officer has acted in accordance with the responsibilities assigned to him/her.
Helaba monitors account-based financial transactions to detect unusual, irregular and unexpected activities. If reason for doubt remains as to whether the transaction serves the purpose of money laundering after intensive clarification and monitoring of the business relationship have been carried out and after the transaction, the customer or the source of his assets have been considered, we refrain from the transaction and make a decision as to whether the business relationship should be refused or terminated. Moreover, cases of suspicion in accordance with Criminal Justice Act are reported to the competent prosecution authorities.
Finally, we hereby certify that our bank cannot be deemed a shell bank within the meaning of the USA Patriot Act and that we shall not use our account held with you for the provision of services to shell banks. Helaba Dublin has prepared a Global Certification for use by any financial institution that believes it requires a USA Patriot Act Certification from Helaba Dublin. (please see attached) Please use this form instead of asking Helaba Dublin to complete a separate Certification form.
Patriot Act
Please see http://www. helaba.de website for USA Patriot Act Certification for Helaba Irish Branch .
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Helaba Dublin No. 5 Georges Dock IFSC Dublin 1
Tel 00 353 1 6460 900 Fax 00 353 1 6460 999
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Patricia Waldron Compliance Officer Tel. (+353) 1 6460 914 E-Mail: Compliance
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