Anti-Money Laundering Statement

Anti-Money Laundering/ Countering Financing of Terrorism / Countering Proliferation Financing (AML /CFT/CPF) Policy Statements

LOTUS Bank is committed to the adoption of best practice in its implementation of a robust AML/CFT/CPF Compliance program. The bank has established policies and procedures that are designed to comply with all extant and emerging local and international laws, regulations, and guidance relating to the prevention of money laundering, terrorist financing, proliferation financing and any other related financial crimes wherever it operates.

The LOTUS Bank AML/CFT/CPF Policy is approved by the board of directors. The policy mandates the bank, its employees, top management, board, vendors, customers and other relevant stakeholders to take all reasonable and appropriate steps to prevent persons engaged in money laundering, terrorist financing, proliferation financing, cybercrimes, fraud, and other financial crimes, including all predicate offenses from utilizing the Bank's products and services.

The objectives of LOTUS Bank AML/CFT/CPF Policy are as follows:

a) To comply with applicable laws and regulatory guidelines on money laundering, terrorist financing and proliferation financing.

b) To guard against LOTUS Bank’s products and services being used to launder the proceeds of crime or fund terrorists’ activities or proliferation financing.

c) To establish processes for customer identification and acceptance programs.

d) Facilitate Board of Directors oversight function in addressing the potential risks of Money Laundering; Terrorist Financing and Proliferation Financing (ML/TF/PF), wherever the Bank operates.

e) Put in place appropriate controls for detection and reporting of suspicious activities and other regulatory returns in accordance with applicable laws/laid down procedures

f) To ensure that all staff members, top management, and board members of the bank are adequately trained and made aware of their obligations and the need for vigilance in the fight against money Laundering, financing of terrorist activities and proliferation financing.

g) Ensure that the policy does not undermine the cordial relationship between LOTUS Bank Limited and her credible customers and relevant stakeholders such as vendors, consultants, regulators, investors, correspondent banks, etc.

Prohibitive Risks

LOTUS Bank will not deal with the following individuals or entities that are involved in the following:

a) Issuers of bearer’s shares

b) Casino’s business

c) Gambling,

d) Nightclubs

e) Sales of Alcohol, Pork products, or other meat that is not slaughtered according to sharia law.

f) Shell Companies / Banks

g) Tobacco

h) Pornography

i) Production or sale of dangerous, radioactive or toxic substances which may carry substantial human or environmental risks (weapons of mass destruction)

j) Cryptocurrency trade / exchange

AML/CFT/CPF Controls

• Lotus Bank uses the risk assessment process to categorise products, channels, customers, and locations that are more vulnerable to money laundering, terrorist financing and proliferation financing.
• The bank assigned responsibility for AML/ CFT / CPF compliance to a designed person who is accountable for the day-to-day compliance activities and keep senior management and the Board informed. An executive compliance officer is also appointed at the board level.
• Policies and procedures are board approved and these are cascaded to every employee in all locations where the Bank operates.
• Implement risk-based Customer Due Diligence (CDD) policies to help identify vulnerable customers.
• Provided dual control and segregation of duties as appropriate.
• Report and maintain records as required by regulation/ law.
• Independent audit of the compliance function in the bank.