Sales and Distribution Department
Correspondent Banking Department
Economic and Financial Information
Code of Ethics and Professional Conduct
Complaints and Customer Service
Data Protection and Confidentiality
Corporate Governance and Remuneration Policy
Appointments and Remuneration Committee
Joint Audit and Risk Committee
Professional Ethics and Conduct
At Bank of Africa Europe, we have developed and implemented guidelines for good conduct in our operations to preserve our reputation and ensure that all staff adhere to ethical and professional standards.
Our code of ethics, grounded in legal and regulatory requirements, establishes the fundamental principles that guide the behaviour and attitude of Bank of Africa Europe's employees in interactions with all parties involved in our operations, including customers, supervisory and regulatory bodies, suppliers, and staff.
Considering the diverse geographical and cultural contexts in which Bank of Africa Europe operates, we must remain especially vigilant in combating fraud and corruption. Ensuring integrity across all our processes is fundamental to our identity, and we have zero tolerance for any form of corruption, whether active or passive.
Our commitment to preventing fraud and corruption is outlined in the basic principles of our Code of Ethics, which is part of a specific policy dedicated to this issue. This reference document consolidates the principles that our entire team must adhere to in their daily decision-making and interactions with third parties. It also promotes effective internal communication to detect any actions that may contravene these principles.
Financial Security
Wolfsberg Financial Crime 2021.
Act 10/2010 on the Prevention of Money Laundering and Terrorist Financing aims to protect the integrity of the financial system and other economic sectors by establishing prevention obligations for money laundering and terrorist financing. These obligations apply to all financial institutions within the European and Spanish banking systems.
This law sets out the principles and criteria for preventing money laundering and terrorist financing, which form the foundation of our procedures and activities. Our entire team is required to understand and adhere to these principles, both in internal management and when dealing with third parties. To ensure compliance, we have developed and implemented the necessary policies in line with current regulations, fulfilling all required communication and reporting obligations. We are also supervised by SEPBLAC (Executive Service of the Commission for the Prevention of Money Laundering and Monetary Offenses) for these purposes.
A key obligation for us is Know Your Customer (KYC), This term refers to the processes we implement to ensure a deep understanding of our clients and continuous monitoring of their activities. This thorough knowledge aids in preventing money laundering and terrorist financing by allowing us to accurately identify the origin and destination of funds, verify the consistency of customers’ banking and financial activities, and understand the economic, financial, and asset background of all parties involved. This ensures that our operations comply with established rules and principles.
Consequently, it is crucial to clearly identify all individuals involved in transactions, as well as the ultimate beneficial owner behind them.
Money laundering is a criminal offence involving the process of legitimising funds derived from illegal activities, affecting all levels of involvement or complicity.
Terrorist financing involves providing and gathering funds for use in terrorist activities.
As central players in global financial systems, banks have obligations and responsibilities to combat money laundering and terrorist financing. They must implement all necessary mechanisms and controls to detect such operations effectively.
Bank of Africa Europe continuously reviews and implements necessary control standards across all its processes, including internal procedures, computer systems, and databases, in compliance with relevant regulations and principles.
In addition, the bank runs an awareness and continuous training programme for all staff, which serves as an essential preventive measure and ensures compliance with legal requirements.
In line with international, European, and national regulations, Bank of Africa Europe implements the necessary controls to comply with current restrictive measures against states, countries, territories, entities, and individuals. These measures may include trade or financial sanctions that prohibit certain operations and transactions and/or require the freezing of assets of specific persons or entities.
To enforce these measures, the bank employs an effective system for screening, analysing, and blocking any transaction that shows even the slightest hint of violating these rules.
According to the regulations set by the US Treasury Department and the USA PATRIOT Act, financial institutions wishing to maintain a USD correspondent account with a US entity must possess the relevant certificate.
In this context, Bank of Africa Europe, as an active participant in the international market, maintains USD accounts with US correspondent institutions and complies with the necessary certification requirements.
Market Integrity
For Bank of Africa Europe to operate smoothly, a robust conflict of interest policy is essential.
Conflicts of interest can arise in various situations, both internally and externally, affecting employees and clients. These are addressed and managed according to the guiding principles outlined in the Code of Ethics (point 3.2).
In line with the FATCA regulations, enacted by the US Congress in 2010, and the agreement signed between Spain and the US in 2013, measures have been established to facilitate the cooperation of financial institutions with US tax authorities, enhancing compliance with tax obligations in both countries.
Bank of Africa Europe has complied with the IRS registration process and has been assigned a Global Intermediary Identification Number (GIIN). Additionally, the necessary internal measures for managing identification information have been implemented for this purpose.
Drawing on the information exchange framework established by FATCA, the OECD initiated the process of adopting a similar system, which Spain joined by adapting its tax regulations in 2015.
This framework, known as the Common Reporting Standard (CRS), sets obligations similar to those of FATCA. It requires the identification of clients' tax residencies and the ultimate beneficial owners or those with control over legal entities, to ensure accurate reporting to the Tax Agency.
The protection of personal data is a fundamental right for everyone, and Bank of Africa Europe is committed to implementing the necessary measures to manage information about our operations, customers, and suppliers.
In line with EU Regulation 2016/679, known as the General Data Protection Regulation (GDPR) of 27 April 2016, we have established internal procedures to manage and control the information in our databases across all levels, including customers, staff, and transactions.
