Effective Date: July 1, 2025
This Anti–Money Laundering (AML) and Counter-Terrorist Financing (CTF) Policy outlines the principles and controls implemented by UEB Bank (“we,” “us,” or “our”) to prevent and detect money laundering and terrorist financing activities.
UEB Bank is committed to full compliance with all applicable laws and regulations in Luxembourg and the European Union, including:
• The EU Anti-Money Laundering Directives (AMLD 5 & 6);
• The Law of 12 November 2004 on the fight against money laundering and terrorist financing, as amended;
• The Regulations and Circulars of the Commission de Surveillance du Secteur Financier (CSSF); and
• Applicable guidelines of the Financial Action Task Force (FATF).
This policy applies to all employees, directors, consultants, and service providers of UEB Bank involved in the provision of banking and financial services.
UEB Bank’s AML/CTF objectives are to:
1. Prevent the use of the Bank’s services for money laundering or terrorist financing.
2. Comply with all legal and regulatory obligations in Luxembourg and the EU.
3. Maintain a robust internal control framework to detect and deter suspicious activity.
4. Ensure all employees understand their obligations through training and awareness programs.
5. Cooperate fully with competent authorities and regulators.
• Money Laundering refers to any process that conceals the origin of funds obtained through criminal activity, making them appear legitimate.
• Terrorist Financing involves providing or collecting funds with the intention or knowledge that they will be used to carry out terrorist acts.
These activities are prohibited under Luxembourg and EU law, and severe penalties apply for non-compliance.
UEB Bank applies a risk-based approach (RBA) to identify and manage potential AML/CTF risks.
We assess the risks associated with:
• The nature of the customer (individual or business, PEPs, etc.);
• The customer’s geographic location;
• The products and services used; and
• The delivery channels (in-person, online, etc.).
Enhanced due diligence (EDD) is applied to higher-risk customers or transactions.
We conduct Customer Due Diligence on all customers before establishing any business relationship or executing significant transactions.
Before opening an account, we verify the identity of each customer using reliable, independent documents and data, including:
• For individuals: government-issued ID (passport or national ID), proof of address, and date of birth.
• For businesses: incorporation documents, ownership structure, and details of beneficial owners.
We may request information or documents to establish the source of funds and source of wealth, particularly for high-value transactions or complex financial structures.
We continuously monitor account activity to detect unusual or suspicious behavior inconsistent with a customer’s profile. All transactions are screened and assessed to ensure compliance with applicable laws and sanctions lists.
UEB Bank conducts enhanced due diligence for Politically Exposed Persons (PEPs) and their close associates or family members, in accordance with EU AMLD and CSSF guidelines.
For higher-risk situations, UEB Bank applies additional controls, including:
• Obtaining senior management approval before establishing or continuing the business relationship;
• Increased frequency of transaction monitoring;
• More detailed verification of the source of funds; and
• Regular review and updating of customer information.
UEB Bank performs ongoing screening of customers and transactions against relevant international sanctions lists, including those issued by:
• The European Union (EU);
• The United Nations (UN); and
• The Office of Foreign Assets Control (OFAC)
Transactions or relationships involving sanctioned entities or individuals are immediately flagged and escalated for review.
All UEB Bank staff receive initial and ongoing training on AML/CTF compliance.
Training covers:
• Recognition of suspicious activity and red flags;
• Reporting obligations;
• Record-keeping requirements; and
• Legal and regulatory updates.
Staff are required to stay informed about their responsibilities and apply AML/CTF procedures consistently.
UEB Bank maintains all customer identification, verification, and transaction records for the period required under applicable law. This ensures that records are available to authorities and regulators upon lawful request.
UEB Bank cooperates fully with competent national and EU authorities in preventing and detecting money laundering and terrorist financing.
We respond promptly and transparently to requests for information or assistance from supervisory and law enforcement agencies.
UEB Bank maintains robust internal procedures for identifying and escalating suspicious transactions.
Employees are required to report any unusual activity through internal compliance channels without delay. All such reports are reviewed by senior compliance staff and handled confidentially.
UEB Bank’s AML/CTF framework is subject to regular independent audits and compliance reviews to ensure effectiveness and continuous improvement.
Findings are reported to senior management and corrective measures are implemented promptly.
This policy is reviewed annually or whenever there are significant legal, regulatory, or operational changes. Any updates are approved by senior management and communicated to all relevant employees.
For questions or further information regarding this policy:
Email: support@ueb-lux.com
