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Anti-Money Laundering

Anti-Money Laundering (AML) and Counter-Terrorist Financing (CTF) Policy Statement

Cathay Bank is firmly committed to participating in international efforts to adhere to sanctions compliance, to combat money laundering and the funding of terrorist activities.

Cathay Bank’s Enterprise-wide Financial Crime Compliance Program

Cathay Bank is committed to participate in the international efforts to combat money laundering and terrorist financing. Cathay Bank has developed a comprehensive compliance program to comply with Anti-Money Laundering (AML), Counter the Financing of Terrorist (CFT), OFAC Sanction, and Foreign Corrupt Practices Act (FCPA) laws and regulations.


Governance Framework

Cathay Bank’s Board of Directors (Board) and senior managers oversee the Bank’s AML/CFT/OFAC and FCPA compliance program (Program). Cathay Bank has designated an enterprise-wide Chief Financial Crimes Management Risk Officer (Officer), who is accountable for the design and operation of the Program. The Officer has direct access to, and regular communication with, senior managers and the Board, who are responsible for approving changes to the Program. The Officer also provides regular reports on the operations and effectiveness of the Program.

Cathay Bank Hong Kong branch has a designated money laundering reporting officer responsible for overseeing compliance with the Program in the branch.

Business units maintain appropriate processes to manage the risks associated with their business activities. Internal Audit provides enterprise-wide independent assurance to senior management and the Board on the effectiveness of financial crimes risk management practices.


Policies and Procedures

Cathay Bank has documented policies and procedures establishing its enterprise-wide requirements regarding the various components of the Program. These policies and procedures are consistent with the requirements of U.S. and Hong Kong regulatory bodies. All policies are published internally and accessible to Bank team members.

Financial crimes risk management principles that govern Cathay Bank’s Program include:


Risk Assessment 

AML/CFT/FCPA and OFAC risk assessments are conducted annually and consider the following risk factors to ensure that the appropriate internal controls are in place to mitigate identified risk:


AML Transactional Monitoring and OFAC Screening

AML and OFAC systems and tools are regularly tuned to ensure the model is effective and is functioning as intended to its full potential. Independent model validators periodically assess the models and report their effectiveness to the Board and appropriate senior managers.

Cathay Bank has no appetite to allow its products or services to be used to facilitate money laundering, terrorist financing, human trafficking, or any activity that is prohibited by laws and regulations.   


KYC Program

Cathay Bank maintains Know Your Client (KYC) requirements, processes and procedures in compliance with applicable regulations. The Bank takes a risk-based approach to KYC, which includes client identification; verification based on reliable independent source documents, data or information; identification of material beneficial owners; politically exposed persons (PEP) and sanction exposure determination; client risk rating, and ongoing due diligence.


Training Program

Cathay Bank’s Board, senior managers and team members are trained annually. Team members receive formal and updated training, including an assessment of their knowledge.


Independent Testing

Cathay Bank‘s Internal Audit department conducts independent, risk-based testing of the Program controls and provides an independent assessment of the effectiveness of the enterprise-wide Program to the Board and applicable senior managers.


Records Retention

As a part of the Program, Cathay Bank maintains records of relevant related documents as required by applicable laws and makes them accessible within the timeframes required by such pertinent laws.

For additional information about Cathay Bank’s AML, CFT, OFAC Sanction and FCPA, please refer to Wolfsberg Due Diligence Questionnaire.

Wolfsberg Correspondent Banking Due Diligence Questionnaire

Cathay Bank has completed the Wolfsberg Correspondent Banking Due Diligence Questionnaire, for use and review by any financial institution that requires more detailed information about Cathay Bank's AML/CTF and OFAC/Sanctions compliance programs. Please click below to view/print the questionnaire. 

Patriot Act Certification

Cathay Bank has prepared a global certification for use by any financial institution that requires a Patriot Act Certification (PAC) for a Cathay Bank foreign entity. Please click the below link to view/print our Patriot Act Certification. 


Have Questions?

If the Cathay Bank business that maintains a correspondent account with your institution is not listed in our PAC or if you have questions regarding any of the above AML information, please contact  [email protected].


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