Stern Bank has stringent guidelines and initiatives in place to assist its employees to understand and avoid compliance violations related to anti-money laundering, information protection and privacy, conflicts of interest and more.
All prospective customers shall be subject to Stern Bank’s Know Your Customer (“KYC”) identification procedure, in compliance with the entity’s AML and KYC Policies. Stern Bank also complies with the reserve requirements set forth under Article 4 of Act No. 273 – 2012, as amended, known as the “International Financial Center Regulatory Act” (“IFCRA”), and applicable regulations.
Stern Bank’s new customer onboarding procedures are designed to verify beneficial ownership, current legal standing of the entity and proper licensing. Background checks will be conducted with the assistance of several compliance tools to which Stern Bank subscribes. As part of Stern Bank’s due diligence process, each applicant undergoes a risk assessment analysis to identify key risk areas that serve as the basis for issuing a risk rating. Risk ratings determine the level of periodic oversight and review for each customer. Stern Bank’s officers are responsible for conducting customer identification due diligence reviews. Final account approval comes from Stern Bank’s Chief Compliance Officer or its designee, when it is clearly documented that Stern Bank has been able to establish a solid understanding of an applicant’s background and business model. A primary objective of KYC policy is to ensure only legal movement of money takes place at Stern Bank. The risk that illegal deposits will make their way into Stern Bank are greatly mitigated as all deposit customers will be parties which have been previously established within the Stern Bank network and have been thoroughly vetted. Once onboarded, the Payments/Deposit Officer will be responsible for client support and reporting.
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