AML/CFT

Intesa Sanpaolo has implemented the anti-money laundering and anti-terrorist financing regulations in accordance with the international/EU/national regulations.

The international community has made the fight against money laundering and the financing of terrorism a priority. 

Money laundering is the process of concealing the illicit origin of proceeds of crimes. Terrorist financing is the collection or the provision of funds for terrorist purposes. “Terrorism” can be defined as the intentional and systematic use of actions designed to provoke terror in the public as a means to certain ends. Terrorism can be the act of an individual or a group of individuals acting in their individual capacity or with the support of a State. It may also be the act of a State, whether against the population (human rights violations such as forced labour, deportation, genocide, etc.), or in the context of an international armed conflict against the civil population of the enemy State. In the case of money laundering, the funds are always of illicit origin, whereas in the case of terrorist financing, funds can stem from both legal and illicit sources.

Money launderers and terrorist financiers exploit loopholes and differences among national AML/CFT systems and move their funds to or through jurisdictions with weak or ineffective legal and institutional frameworks.

Money laundering and the financing of terrorism are financial crimes with economic effects. Effective anti-money laundering and combating the financing of terrorism regimes are essential to protect the integrity and stability in financial markets.

With regard to the sustainable growth, matter to which Intesa Sanpaolo Group pays great attention, it has to be highlighted that the “UN Sustainable Development Goals” call on countries to significantly reduce illicit financial flows by 2030.

Illicit financial flows refer to the movement of money across borders that is illegal in its source (e.g. corruption, smuggling), its transfer (e.g. tax evasion), or its use (e.g. terrorist financing).

Illicit financial flows constitute a major disabler to sustainable development. They can have a direct impact on a country’s ability to raise, retain and mobilise its own resources to finance sustainable development.

Intesa Sanpaolo implemented international/EU/national AML/CFT rules:

  • adopting - also at group level - policies and procedures as well as the “Guidelines for combating money laundering and terrorist financing and for managing embargoes” that indicate the choices made on the relevant profiles in matter regarding the organization, procedures and internal controls, customer due diligence and storage of data;  and

  • organizing special ongoing training programmes to help employees in recognise operations which may be related to money laundering or terrorist financing and to instruct them as to how to proceed in such cases.

In order to allow the counterparties to comply with the due diligence obligation, among other things, the following documentation is made available to them:

  • the “Certification regarding Correspondent Accounts for Foreign Banks” maintained with any U.S. bank or broker-dealer in securities made under USA PATRIOT Act (Uniting and Strengthening America by Providing Appropriate Tools to Intercept and Obstruct Terrorism Act) of 2001 by Intesa Sanpaolo SpA and the companies belonging to the Group;

  • the “Wolfsberg Group Correspondent Banking Due Diligence Questionnaire (CBDDQ)” of Intesa Sanpaolo Spa and of the companies belonging to the Group containing the information on the structure and on the procedures adopted by them aimed at preventing of the use of the financial system for the purposes of money laundering or terrorist financing.

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