Guaranty Trust Bank Tanzania (“the Bank”) is dedicated to the combating of financial crimes, including money laundering and terrorist financing. In this regard, the Bank has implemented a framework for Anti-Money Laundering (“AML”), Combating the Financing of Terrorism (“CFT”) and the prevention of the financing and proliferation of weapons of mass destruction.
The framework ensures adherence to AML/CFT legislation and regulations in Tanzania as well as leading best practices including but not limited to the Financial Action Task Force (FATF) 40 Recommendations.
Policies and procedural guidelines have been set up by the Bank and are regularly reviewed/revised to ensure that they remain relevant and current and are in line with the evolving regulatory requirements and leading practices.
The Bank has moved away from a “rule based and tick box” approach for combating financial crime risk, to a risk based approach. Thus, the Bank identifies and assesses the risks from a proactive stance and allocates the requisite resources which center around systems and controls to manage these risks.
The scope of the Bank’s AML/CFT framework covers the following:
The Board of Directors of the Bank has oversight responsibilities for the AML/CFT framework. The Board ensures that the Bank’s Management and all employees conform strictly with all regulatory and internal procedures relating to AML/CFT and that the Bank maintains a zero tolerance to regulatory infraction. In accordance with AML/CFT global best practice, the “tone is set from the top”.
AML & CFT reports are submitted monthly and quarterly to senior management and the Board respectively. These reports provide the Board and senior management with information to enable them assess the Bank’s compliance with its regulatory obligations. The reports also ensures that Directors and senior management are kept abreast on current trends and developments in the financial industry, particularly in the area of AML/CFT risk management.
A duly completed account opening form and the collection of identification and other relevant information and documents are the foundation/bedrock for on-boarding a customer in the Bank. Customer Due Diligence (CDD) is conducted prior to entering into any banking relationship with a customer. This includes at a minimum, identity and address verification as well as ascertaining the source of income and wealth of the customer.
Enhanced Due Diligence (EDD) is conducted on high risk customers including politically exposed persons. The approval of senior management and Compliance is required prior to the commencement of banking relationship with such high risk customers.
The Bank takes requisite and regulatory measures when embarking on relationships with Designated Non-Financial Businesses and Professionals (DNFBPs), due to their perceived risk and in compliance with regulatory requirements.
As part of the Bank’s KYC and CDD procedures, identification documents are requested and obtained to confirm the beneficial owners of a business and the organization’s control and structure.
Transaction monitoring occurs on a manual and automated basis. The former is performed by all members of staff, who are regularly provided with red flags to look out for and the latter resides within the Compliance Unit.
All members of staff are aware of the fact that suspicious activities/ transactions should immediately be referred to the Compliance Unit.
Regulatory and statutory requirements provide that certain reports and returns are made to regulatory bodies. In Tanzania, the Financial Intelligence Unit (FIU) is the agency charged with the responsibility of receiving suspicious transaction reports Section 17 of the Anti-Money Laundering Act 2006, provides that a financial institution must submit reports on all unusual and suspicious transactions.
All suspicious transactions deemed reportable to the regulator is prepared and rendered in the approved format to the FIU in accordance to Section 17 of the AMLA.
The Bank understands that part of its corporate and social role is to cooperate with law enforcement agencies in the fight against financial crime. To this end, the Bank maintains a cordial and supportive relationship with all regulatory and law enforcement agencies. The Bank promptly complies with all requests made, pursuant to the law, and provides information to regulators including the BOT, FIU and other relevant agencies.
The Bank as a policy, does not enter into any relationships with sanctioned individuals/entities. All employees, as applicable to their functions, are required to screen names of individuals and organizations who have or plan to enter a business relationship or carry out a transaction with/through the Bank against the Bank’s internal watch list.
The internal watch list contains the names of individuals and entities, who have been blacklisted by various sanctions bodies. Employees are required, as part of the Bank's policy, to refrain from any relationship and/or transaction which yield a true or positive match and follow the escalation procedure. Sanctions screening is done at account opening and on a real time basis for all SWIFT transactions.
PEPs are individuals who are or have been entrusted with prominent public functions and people or entities associated with them. Enhanced due diligence measures are applied to PEPs, as with other high risk customers to mitigate the AML/CFT risk they pose. This is to ensure that the Bank is not unknowingly supporting fraudulent activities such as money laundering and/or the financing of terrorism.
In line with FATF's recommendation, the Bank employs the use of an automated monitoring tool in identifying and monitoring PEP transactions. This is achieved through the thorough review of information provided by customers and their transaction trends.
Establishment of new accounts for PEPs as well as continuity of such accounts (for those already existing in the system) is subject to the approval of the Managing Director and the Compliance Unit.
The Bank only enters into and maintains correspondent banking relationships with financial institutions that have implemented sufficient AML/CFT policies and procedures. The Bank does not deal with shell banks nor maintain any payable through accounts. The Bank ensures that due diligence is performed annually on our correspondent relationships to avoid AML/CFT risks.
The Bank as a policy, places a high value on the training of its employees. Trainings are carried out to ensure employees are conversant with the AML/CFT laws, KYC principles and other AML/CFT related information. Annual Compliance training is mandatory for all members of staff, including Senior Management. Trainings are done via e-learning or face to face. Training also takes place by way of the dissemination of topical national and international findings to employees.
In order to adhere to regulations and to ensure an ever evolving fit for use Compliance function, internal audit of the AML/CFT function is conducted on a regular basis. The purpose of the audit is to test for, and ensure the effectiveness of the AML/CFT measures put in place by the Bank.
The report and findings of the audit are circulated to various levels of senior management. A follow-up to the audits takes place to ensure that the relevant issues are closed out and highlighted recommendations have been implemented.
As provided for in Anti Money Laundering Act 2006, customer identification documents are retained throughout the life of the account and for ten (10) years after the cessation of the banking relationship, except in cases of litigation and/or regulatory investigations. In the case of the latter, the records will be kept for as long as they are required.