AML Notice
WestLB AG including its affiliates, subsidiaries and offices (collectively “WestLB”) is committed to combating money laundering and terrorist financing. To this end, WestLB has implemented a comprehensive global anti-money laundering (“AML”) program designed to detect and prevent money laundering and terrorist financing activities.
As a bank based in Düsseldorf, Germany, WestLB’s global AML program is designed to comply with German AML laws and regulations as a minimum standard throughout the bank. As a member country of the Financial Action Task Force (“FATF”) and the European Union (the “EU”), the Federal Republic of Germany has enacted laws and regulations that require financial institutions like WestLB to take certain steps to detect and prevent money laundering and terrorist financing in accordance with the policies and recommendations of FATF and the EU. Although WestLB’s global AML program is designed to comply with German law as a minimum standard, WestLB continually adjusts and adapts its AML program to be used by its affiliates, subsidiaries and offices that are located in other jurisdictions to ensure that WestLB’s affiliates, subsidiaries and offices comply fully with the laws and regulations of the jurisdictions where they are located, such as U.S. laws and regulations.
WestLB’s AML program includes, among other things: (i) written policies and procedures; (ii) a designated anti-money laundering compliance officer; (iii) training for relevant employees; and (iv) an independent audit function to monitor the implementation of the AML program. Under its AML program, WestLB takes steps to detect and report suspicious activities as appropriate to regulators and law enforcement authorities. WestLB also operates automated and manual monitoring systems to detect suspicious activities. When a suspicious activity is detected, WestLB makes all required reports to relevant law enforcement and regulatory agencies. In this regard, WestLB also takes steps to ensure that it complies with embargo laws and regulations applicable in the EU and other jurisdictions in which WestLB has offices including maintaining lists that are compiled on the basis of multiple sources including the German Federal Financial Supervisory Authority (Bundesanstalt für Finanzdienstleistungsaufsicht), the EU, and the United States’ Office of Foreign Assets Control (“OFAC”).