Clearstream Banking S.A. ("CBL") conducts its business in accordance with applicable laws, regulations and regulatory guidance governing AML/CFT, sanctions and proliferation financing and supports national and international efforts to protect the integrity of the financial system.
CBL maintains a comprehensive risk-based financial crime compliance program designed to prevent its products and services from being used to facilitate money laundering, terrorist financing, sanctions evasion, proliferation financing or other criminal activity. The program is embedded in the anti-financial crime risk governance, framework, policies, procedures, systems, trainings and oversight controls that are subject to ongoing supervision, reviews, and enhancement where applicable.
This includes, among other measures:
- Enterprise-wide financial crime risk assessments designed to identify and assess risks associated with customers, products, services, geographies, transactions and delivery channels;
- Risk-based customer due diligence and ongoing monitoring procedures, including enhanced due diligence measures where higher risks are identified;
- Customer and transaction screening for sanctions, politically exposed persons and other relevant risk indicators including adverse media;
- Risk-based transaction monitoring and suspicious activity detection and disclosure processes;
- Escalation, investigation and reporting mechanism;
- Measures designed to prevent the misuse of CBL's services for financial crime purposes;
- Record retention and documentation requirements;
- Testing and review of AML/CFT, sanctions and financial crime controls;
- Regular AML/CFT, sanctions and financial crime training appropriate to employees' roles and responsibilities; and
- Group and legal entity Governance, oversight and management reporting.
CBL applies robust Know Your Customer ("KYC") and Customer Due Diligence ("CDD") procedures prior to establishing a business relationship and throughout the lifecycle of that relationship. CBL seeks to identify and verify its customers, understand the purpose and intended nature of the relationship, assess customer risk, maintain customer information up to date and conduct ongoing monitoring consistent with applicable legal and regulatory requirements.
As a regulated financial market infrastructure, CBL's direct customers are primarily regulated financial institutions and other eligible counterparties. CBL generally maintains relationships only with its direct account holders and therefore does not typically possess information relating to the ultimate beneficial owners of assets held by customers on behalf of their own underlying clients. Responsibility for identifying and verifying such underlying beneficial owners remains with the customer maintaining the direct relationship, in accordance with applicable AML/CFT requirements.
In accordance with applicable laws, regulations and internal policies, CBL may reject transactions, restrict services, freeze assets, exit customer relationships, or take other appropriate measures where financial crime, sanctions or regulatory concerns are identified.
Availability of Due Diligence Information
As a matter of policy, CBL does not generally provide bespoke AML attestation letters or institution-specific compliance certifications.
To support counterparties in conducting their due diligence, CBL makes available industry-recognized due diligence documentation, including:
