ICC Bank Anti-Money Laundering Policy

Effective Date: October 17, 2023

1. Introduction

ICC Bank, located in Johannesburg, South Africa, is committed to maintaining the highest standards of integrity and ethics in financial operations. This Anti-Money Laundering (AML) policy outlines our commitment to preventing money laundering and complying with relevant laws and regulations.

2. Legal Framework

ICC Bank will adhere to all AML laws and regulations applicable in South Africa, including the Financial Intelligence Centre Act (FICA) and other relevant legislation. We will also follow international AML standards and guidelines.

3. Customer Due Diligence (CDD)

We will establish and verify the identity of our customers based on a risk-based approach. This includes ongoing monitoring and enhanced due diligence for high-risk customers.

4. Reporting Obligations

ICC Bank will report any suspicious activities to the appropriate authorities, including the Financial Intelligence Centre (FIC), in accordance with South African law.

5. Record Keeping

We will maintain records of customer transactions and related documentation as required by law. These records will be retained for the prescribed period.

6. Training and Awareness

All ICC Bank employees will receive AML training to recognize suspicious activities and comply with our AML policy.

7. Risk Assessment

We will conduct regular risk assessments to identify and mitigate AML risks associated with our operations.

8. Internal Controls

ICC Bank will implement effective internal controls, including the appointment of a Money Laundering Reporting Officer (MLRO) and the development of procedures to ensure AML compliance.

9. Penalties for Non-Compliance

Employees found to be in violation of this AML policy may face disciplinary actions, and the bank may be subject to legal penalties for non-compliance with AML regulations.

10. Review and Updates

This AML policy will be reviewed regularly to ensure it remains effective and compliant with applicable laws and regulations.

ICC Bank is committed to preventing money laundering and will take all necessary measures to comply with the law while providing quality financial services to our valued customers.

Authorized Signature: Mr. Pablo Oageng Seitshiro Chief Executive Officer Date: October 17, 2023