Commitment to Compliance

AFC is committed to the highest standards of integrity, transparency and regulatory compliance, supported by a comprehensive framework to prevent and mitigate financial crime risks.

Our Commitment

Arab Finance Corporation S.A.L. (“AFC”) is committed to conducting its business with the highest standards of integrity, transparency and regulatory compliance and to protecting the financial system from misuse for illicit purposes.

AFC maintains a comprehensive compliance framework designed to prevent, detect and mitigate financial crime risks, including, but not limited to:

  • Money laundering;
  • Terrorist financing;
  • Proliferation financing;
  • Bribery and corruption;
  • Fraud;
  • Tax evasion and the facilitation of tax evasion;
  • Breaches of applicable financial sanctions; and
  • Other forms of financial crime and illicit financial activity.

AFC does not knowingly engage in, facilitate or tolerate transactions or business relationships involving proceeds of crime, terrorist financing, corruption, fraud, sanctions evasion or other unlawful activities.

Regulatory and International Framework

AFC is a Lebanese financial institution regulated by the competent Lebanese regulatory and supervisory authorities and conducts its activities in accordance with applicable Lebanese laws, regulations, circulars and regulatory requirements, including those issued by:

  • Banque du Liban (“BDL”);
  • The Capital Markets Authority (“CMA”);
  • The Special Investigation Commission (“SIC”); and
  • The Banking Control Commission of Lebanon (“BCCL”), where applicable.

AFC also takes into consideration internationally recognized principles, recommendations and standards relevant to combating financial crime, including those issued by the:

  • Financial Action Task Force (“FATF”);
  • Middle East and North Africa Financial Action Task Force (“MENAFATF”);
  • United Nations (“UN”);
  • The European Union (Directives);
  • The Basel Committee on Banking Supervision;
  • The Egmont Group;
  • The Wolfsberg Group; and
  • Other internationally recognized bodies and competent authorities, as applicable.

Sanctions Compliance

AFC is committed to complying with applicable local and international financial sanctions and restrictive measures.

AFC does not knowingly establish or maintain relationships or process transactions that would result in a breach of applicable sanctions requirements.

Where a potential sanctions match or concern is identified, AFC applies the appropriate review, escalation, reporting, blocking, freezing or rejection measures, as required by applicable laws and regulations.

Anti-Bribery and Corruption

AFC adopts a zero-tolerance approach to bribery and corruption.

AFC prohibits its directors, officers and employees from directly or indirectly offering, promising, giving, requesting, accepting or receiving bribes, kickbacks, facilitation payments or any other improper advantage intended to influence a decision or obtain an improper business or personal benefit.

AFC maintains policies and controls addressing bribery and corruption risks, including conflicts of interest, gifts and hospitality, dealings with third parties and other circumstances that may create an actual or perceived corruption risk.

Employees are expected to conduct themselves with integrity, independence, professionalism and transparency at all times.

Politically Exposed Persons

AFC applies enhanced controls to relationships involving Politically Exposed Persons (“PEPs”), their family members and close associates in accordance with applicable regulatory requirements and its risk-based approach.

Such relationships are subject to appropriate enhanced due diligence, approval, source of funds and/or source of wealth assessment, and enhanced ongoing monitoring, as applicable.

Anti-Fraud

AFC is committed to preventing, detecting and addressing fraud.

Appropriate internal controls are maintained to identify and mitigate the risk of fraudulent activities involving customers, employees, third parties or AFC’s products and services.

Suspected fraud is subject to appropriate investigation, escalation and, where required, reporting to the competent authorities.

Tax Compliance

AFC does not knowingly facilitate tax evasion.

AFC maintains appropriate procedures to comply with applicable tax transparency and information-reporting requirements, including the Foreign Account Tax Compliance Act (“FATCA”) and the Common Reporting Standard (“CRS”), where applicable.

Customers are expected to provide complete, accurate and up-to-date information concerning their tax residency and other information required for AFC to comply with its legal and regulatory obligations.

Correspondent and Third-Party Relationships

AFC applies appropriate due diligence before establishing and throughout its relationships with correspondent institutions, custodians, brokers, financial institutions and other relevant third parties.

AFC expects the institutions and parties with which it conducts business to maintain appropriate standards for combating money laundering, terrorist financing, proliferation financing, sanctions violations, bribery, corruption and other financial crimes.

AFC does not establish or maintain correspondent relationships with shell banks and does not knowingly permit its accounts or services to be used by shell banks.

Governance, Training and Independent Review

AFC’s Board of Directors and Senior Management promote a strong compliance culture and support the implementation of effective controls for managing financial crime risks.

AFC maintains dedicated Compliance and AML/CFT functions with appropriate authority, independence and access to information necessary to perform their responsibilities.

AFC employees receive periodic training and awareness on AML/CFT, sanctions, anti-bribery and corruption and other relevant compliance matters according to their roles and responsibilities.

AFC’s compliance framework is subject to periodic review, monitoring and independent testing to assess the adequacy and effectiveness of its controls and to identify areas requiring enhancement.

Continuous Commitment

Combating financial crime is an ongoing responsibility.

AFC continuously reviews and enhances its policies, procedures, systems and controls to reflect changes in applicable laws and regulations, international standards, emerging financial crime risks and the nature of its business activities.

AFC expects its directors, officers, employees, customers and business partners to uphold the principles of integrity and lawful conduct that underpin this commitment.