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Institutional Integrity. Financial Crime Prevention. Regulatory Discipline.

ANTI-MONEY LAUNDERING (AML) & KNOW YOUR CLIENT (KYC) POLICY

International Commerce Bank Singapore (“ICBANKSG” or “the Institution”) is committed to preventing money laundering, terrorist financing, sanctions violations, and other forms of illicit financial activity. This AML & KYC Policy outlines the institutional framework implemented to safeguard the integrity of our banking platform and protect the global financial system.

Policy Objective

1

The objective of this Policy is to:

  • Prevent the misuse of financial services for illicit purposes
  • Identify and mitigate financial crime risks
  • Ensure regulatory compliance across jurisdictions
  • Protect institutional credibility and client trust

ICBANKSG applies a risk-based approach to compliance and client verification.

Risk-Based Compliance Framework

2

ICBANKSG maintains a structured compliance model incorporating:

  • Client risk categorization
  • Jurisdictional risk assessment
  • Sector-specific exposure analysis
  • Transaction pattern monitoring
  • Escalation and review procedures

Higher-risk engagements are subject to enhanced due diligence protocols.

Know Your Client (KYC) Requirements

ICBANKSG conducts structured KYC procedures prior to onboarding any client or engaging in financial transactions.

Individual Clients

3

  • Government-issued identification
  • Proof of address
  • Source-of-funds declaration
  • Professional or business background review

Corporate Clients

  • Certificate of incorporation
  • Memorandum & Articles of Association
  • Director and shareholder registry
  • Identification of ultimate beneficial owners (UBOs)
  • Corporate structure chart
  • Financial documentation

No account activation or financing review proceeds without completion of required KYC documentation.

Beneficial Ownership & Transparency

4

ICBANKSG requires disclosure of ultimate beneficial ownership for all corporate entities. The Institution verifies individuals holding ownership interests, control relationships, and nominee arrangements. Failure to provide transparent ownership information may result in application rejection.

Institutional Commitment

ICBANKSG is committed to protecting the integrity of the financial system, upholding international compliance standards, preventing financial crime, and ensuring disciplined risk management. Compliance is central to our institutional identity and long-term sustainability.

3. Know Your Client (KYC) Requirements

ICBANKSG conducts structured KYC procedures prior to onboarding any client or engaging in financial transactions.

Individual Clients Verification may include:

  • Government-issued identification
  • Proof of address
  • Source-of-funds declaration
  • Professional or business background review

Corporate Clients Verification may include:

  • Certificate of incorporation
  • Memorandum & Articles of Association
  • Director and shareholder registry
  • Identification of ultimate beneficial owners (UBOs)
  • Corporate structure chart
  • Financial documentation

No account activation or financing review proceeds without completion of required KYC documentation.

4. Beneficial Ownership & Transparency

ICBANKSG requires disclosure of ultimate beneficial ownership for all corporate entities. The Institution verifies:

  • Individuals holding direct or indirect ownership interests
  • Control relationships within corporate structures
  • Nominee or intermediary arrangements

Failure to provide transparent ownership information may result in application rejection.

5. Enhanced Due Diligence (EDD)

Enhanced due diligence measures are applied where risk indicators are elevated, including:

  • Politically Exposed Persons (PEPs)
  • High-risk jurisdictions
  • Complex ownership structures
  • Unusual transaction patterns
  • Large-scale cross-border financing

EDD may include additional documentation requests and internal compliance review.

6. Sanctions & Watchlist Screening

ICBANKSG conducts screening against applicable sanctions and international watchlists prior to onboarding and periodically thereafter. Screening may include:

  • Sanctions lists
  • Politically Exposed Person databases
  • Adverse media screening
  • Regulatory enforcement lists

The Institution maintains a zero-tolerance policy for sanctioned or prohibited entities.

7. Ongoing Monitoring

AML compliance does not end at onboarding. ICBANKSG implements ongoing transaction monitoring mechanisms to detect:

  • Unusual transaction activity
  • Inconsistent funding patterns
  • Structuring or layering indicators
  • Jurisdictional risk exposure

Transactions identified as atypical may be subject to further review or reporting.

8. Record Retention

ICBANKSG retains AML and KYC documentation in accordance with applicable regulatory requirements and internal retention policies. Records may include:

  • Client identification data
  • Due diligence documentation
  • Transaction history
  • Internal compliance assessments

Retention periods vary based on regulatory expectations.

9. Reporting Obligations

Where required by law or regulatory directive, ICBANKSG may report suspicious activity to appropriate authorities. All internal reports are handled through confidential escalation procedures.

10. Internal Oversight & Governance

ICBANKSG maintains structured oversight of its AML framework through:

  • Compliance supervision
  • Periodic policy review
  • Internal control assessment
  • Risk management oversight

Compliance procedures are subject to ongoing refinement to align with evolving regulatory standards.

11. Client Responsibilities

Clients are responsible for:

  • Providing accurate and complete information
  • Promptly updating material changes
  • Cooperating with compliance requests
  • Disclosing source-of-funds transparently

Failure to comply may result in service suspension or termination.

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