- US Patriot Act Certification
- Wolfsberg AML Questionnaire

Following the information about the Anti Money Laundering Policies and Procedures of DZ BANK International S.A. (Registre de Commerce et des Sociétés: Luxembourg No. B 15579), to avoid the exploitation of DZ BANK International S.A. (DZI) for the purposes of money laundering and financing of terrorism:

The DZI is subject to inspection by the banking authority "Commission de Surveillance du Sector Financier" (CSSF). The banking license provided by CSSF permits DZI to conduct banking activities. The provision of banking activities obligates DZI to comply with luxembourgish law and regulations regarding the fight against money laundering and financing of terrorism.

DZI maintains mandatory written policies and procedures ("Organisationsrichtlinien") for the prevention of money laundering. These are written in German, consist and determined for internal use only. DZI`s "Organisationsrichtlinien" meet the requirements of the luxembourgish law and regulations regarding the fight against money laundering and financing of terrorism. These include internal control, procedures and yearly training programs for the employees of DZI.

These policies and procedures are mandatory for all DZI operations, including cross-border operations. The observance of the "Organisationsrichtlinien", which implement policies and procedures, is supervised by an independent external auditing firm.

The internal policies and procedures meet the current recommendations of the FATF/GAFI. Luxembourg is a member of the OECD-Organisation FATF/GAFI (Financial Action Task Force on Money Laundering / Groupe d'action financière sur le blanchiment de capitaux). Luxemburg is also a member state of the European Union (EU).

The procedures require the beneficial owners of corporate entities to be verified in line with the requirements regarding customers (being natural persons or legal persons). The duty to identification relates to any person involved / person acting.

The procedures require retention of the relevant KYC records. The period of conservation of AML-records for DZI is minimum six years after ending the business relation.

Suspicious transactions have to be reported to the Financial Intelligence Unit (FIU) of the Public Prosecutor of Luxembourg and the banking authority (CSSF). The procedures require with respect to the execution of suspicious transactions a prior release by the FIU.

DZI neither provides correspondent banking services nor maintains accounts for "Shell Banks".

The list of names of shareholders from the DZ BANK International S.A.:

Should you require any further information do not hesitate to contact us.

DZ BANK International S.A.
Department Legal/Compliance/AML
Boite postale 661
L-2016 Luxemburg
Tel.: 00352 44903-5110
Fax: 00352 45 73 93

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Stand: 02/2008