Financial Crime Risk Appetite Statement

BCB Group is committed to respecting its legal and regulatory, ethical and social responsibilities to protect our clients, our people, our stakeholders and partners and to support regulatory and law enforcement authorities in economic crime prevention. It is the policy of BCB Group to conduct business with integrity and in an honest and ethical manner in all its business dealings and relationships, wherever it operates.

BCB Group operates a three-lines-of-defence model and has in place a comprehensive financial crime management framework, comprising policies, procedures, systems and controls to combat the risk of financial crime and continually strives to ensure that accounts held at BCB are not misused for the purpose of facilitating financial crime. On an annual basis, BCB Group regulated entities commission an independent assurance review of the effectiveness of its financial crime framework. 

BCB Group expects its own customers to operate in a manner that is consistent with BCB Group’s own compliance standards and risk appetites. We expect clients to conduct themselves with integrity, openness and full transparency and are required to demonstrate they have in place a robust financial crime risk framework.

Our Risk Appetite Statement (RAS) defines the boundaries within which we operate to protect our clients, our banking partners, and the integrity of the global financial system: –

1. 1. BCB has a zero tolerance approach to knowingly engaging in or facilitating financial crime. This zero tolerance applies to all activities by BCB staff or associated persons which amount to a breach of financial crime laws and regulations. While our risk appetite is zero tolerance, we acknowledge that the complete elimination of financial crime exposure is not always possible in practice. Our commitment is to never knowingly turn a blind eye to risks we become aware of, and to respond promptly and decisively once risks are identified and investigated.
   2. BCB maintains a zero risk appetite for certain high-risk sectors and activities. BCB will not enter into business relationships with entities or individuals actively involved in the following sectors, nor will it knowingly facilitate related transactions:

• Unregulated or unlicensed money service businesses (MSBs). 

• Shell Banks or Shell Companies lacking verifiable economic substance.

• Illegal sale or distribution of recreational drugs; Human trafficking, modern slavery, and any other illegal activity.

1. BCB has a zero risk appetite for servicing any clients established in prohibited risk jurisdictions or out-of-appetite risk jurisdictions. BCB has a zero risk appetite for handling transactions in prohibited risk jurisdictions or out-of-appetite risk jurisdictions. Prohibitive risk countries are those where BCB is prohibited from providing its products and services due to regulatory prohibitions or because they are subject to sanctions. BCB also maintains “out-of-appetite” risk countries where the BCB Board has determined present an unacceptable risk (but which are not legally restricted) and has therefore determined not to offer or provide its products and services. 
2. BCB has a zero risk appetite for any involvement in facilitating deliberate or knowing participation (directly or indirectly through its clients) in activities which amount to a breach of financial crime laws and regulations in the countries in which we operate or that apply to our business, our operations and the transactions we undertake. This applies in particular to money laundering, terrorist financing and proliferation financing. 
3. BCB has a zero risk appetite for doing business with any designated individuals, businesses or countries which are on applicable sanctions lists. BCB has a zero risk appetite for breaches of sanctions. This means BCB has a zero risk appetite for its direct clients or their transactions being confirmed to involve any designated individuals, businesses or countries which are on applicable sanctions lists. 

BCB Group maintains a zero risk appetite for all forms of (given or received) facilitation payments, bribery, or corruption in any jurisdiction, whether carried out by its own people or its associated persons. BCB maintains a zero tolerance for the criminal facilitation of tax evasion by any associated person.