In order to ensure a common consistent approach throughout the Group, Dexia has drawn up a series of general policy guidelines on the basis of which all units have adopted procedures and instructions setting out obligations and formalities applicable to:
- a knowledge and identification of customers, representatives, proxy-holders and economic beneficiaries;
- cross-checks against official lists of criminals, terrorists, nuclear proliferators, …, issued by national and international authorities (sanction lists: ONU, OFAC et UE);
- the monitoring of account and business during the term of the relationship;
- the monitoring of operations and detection of suspicious transactions;
- cooperation, with the regulatory and judicial authorities in the event of suspicion of money laundering or terrorist financing in accordance with applicable requirements.
In the United States the Dexia Group fulfils the requirements of the American authorities regarding the fight against the financing of terrorism and money laundering. Moreover, through the USA Patriot Act, foreign banks maintaining relations with an American bank or American broker/dealer are required to meet global certification requirements (See the list of branches and subsidiaries of the group covered by that certification.)