According to local law, laundering of the proceeds derived from crime by using financial systems and to be used for terrorism financing is considered crimes.
Main function of financial intelligence units (FIU) operating in many countries in today's world is to prevention of money laundering and combating financing of terrorism. In our country, this role is conducted by Financial Crimes Investigation Board (MASAK), which operates under the Ministry of Treasury. Many financial institutions, including our company are defined as “obliged” according to law, regulation and communiqués came into force by MASAK to prevent money laundering and combating financing of terrorism and in this context, many requirements are structured for obliged companies and its employees for effective risk management.
You can reach the legislation on main principles, obligations and penalties that have to comply by our Company and our employees at the following address:
Knowing our customers, business partners and suppliers and getting information about them are the part of AvivaSA’ risk management framework. Our company has established measures to prevent the use of products and services offered to customers for financial crimes, such as money laundering and terrorist financing, in accordance with current risk management policies. In this sense, the necessary identification and verification processes are implemented in accordance with MASAK legislation and our shareholders -Aviva Group and Sabancı Holding- policies. In addition, actions are taken such as not establishing a business relationship with risky people and organizations or enhanced due diligence, not conducting risky transactions requested by employees or third parties and evaluating legal reporting obligations in suspicious transactions.
The examples given below are considered as suspicious transactions.
Manage the risk of financial crimes and to comply with the legislation, the following activities are carried out in summary by the Regulatory Compliance and Financial Crime Management:
According to the risk appetite framework adopted by AvivaSA Board of Directors, AvivaSA has a responsibility to protect customers, shareholders and the society from financial crimes.
Intentional or repeated breaches of law, regulation or policy related to financial crime.
Recognizing that financial crime risk events of this nature will occur, AvivaSA will tolerate accidental breaches with a limited extend.
Conducting business relationship with customers and related parties or counterparties from special risk rated countries without an allowable exception.
AvivaSA has limited appetite for conducting business in, involving, with, or on behalf of, customers and counterparties based in or from special risk rated special risk countries.
Acts of intentional facilitation of tax evasion by employees, representatives or other persons associated to AvivaSA.
AvivaSA seeks a continually improving trend in managing this risk and ensures any accidental or intentional risk events of this type are reported and investigate.
Acts of bribery and corruption by an employee or person associated with AvivaSA. This would include:
Intentionally accepting assets suspected of criminal income without legal entitlement.
AvivaSA has zero tolerance for conducting business with prohibited customer or segments. AvivaSA has limited tolerance for conducting business with restricted customer or segments.
Acts of fraud or dishonesty perpetrated by employees, directors or representatives of AvivaSA.
AvivaSA has no appetite for acts of fraud or dishonesty directed against or enabled through AvivaSA by customers, suppliers, distributors and third parties (including those with no business relationship).
AvivaSA seeks a continually improving trend on instances of fraud loss or acts of dishonesty.