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Anti – Money Laundering & Counter Terrorist Financing Policy

Anti – Money Laundering


  Counter Terrorist Financing Policy

 April 2014





It is the policy of Gamesilk to prohibit and actively pursue the money laundering and any activities  that facilitates money laundering or the funding  of terrorist or criminal activities.   

The company is committed to AML/CTF  compliance in accordance with  applicable law and requires its management and employees   to adhere  to  these  standards   in preventing the use of its products  and services for  money   laundering   purposes.   Therefore   inline with Know Your Customer Principle, it is essential to identify the customers and those who carry out transactions on behalf of the customers, and it is forbidden to open anonymous accounts  and to conduct transactions with shell banks.

The  company’s  branches   and   subsidiaries,  regardless  of   their    geographic   location, must adhere to this policy provided that it does not conflict  with the  applicable  AML/ CTF legislation of their host country. 

The  company  has  established   a   Compliance   Department  and  designated   a Compliance Officer in order to ensure the compliance to  applicable  AML/CTF  laws, rules  and regulations.

 The Compliance Officer is entitled to demand and access all kinds of information and documents from all units within the Gamesilk, regarding its own area of duties, in order to make a decision at his discretion  independently.



AML/CTF  related   risks   are   defined, rated  and the  necessary  precautions  are taken  to monitor, assess and reduce these risks.

Risk management activities include but are not limited to the following: 
  • Developing methods to identify, rate,  classify and assess  risks based on customer risk, service risk and country risk,
  • Rating and classifying services, transactions and customers according to risks,
  • Procuring that risky customers, transactions or services  are monitored, controlled and reported   to   warn  the  relevant  units,  and  developing   appropriate operational and control guidelines to  ensure  that  the   transactions   are   carried out  with  a  senior’s approval,  and controlled when necessary,
  • Questioning the consistency and  effectiveness  of  risk  identification   and evaluation methods,  risk rating and classification methods  using case studies or retrospectively  through real-life transactions; re-evaluating and updating  such methods  according to the conclusions arrived  and the conditions that prevail,
  • Conducting  necessary   improvement   studies  taking    into    consideration   the national legislation governing issues which involve risks as well as recommendations,  principles, standards  and guidelines introduced by international institutions,
  • Reporting the results of risk monitoring  and evaluation to the Board  of Directors  at regular intervals,
  • Taking additional measures against  high risk groups.
Activities falling within this scope are executed  by the Compliance Department.


The purpose of monitoring and control is to protect  the Bank against  risks and to monitor and control  on a permanent basis whether the Bank's operations are carried out in accordance with the Law and other arrangements issued as per the Law as well as the Bank's  policies   and procedures. 

In  the  framework  of  monitoring  and   control   activities,   defects   discovered   as    a result of controls  carried out to assure  compliance with obligations are reported to the relevant units for necessary  measures to be taken and the outcome  is followed.

As part of monitoring and control activities, the Bank procures  that the personnel  carrying out these activities have access to internal information resources. 

Monitoring and control activities include  but are not limited to the following:

  • Monitoring and controlling customers and transactions in the high risk group,
  • Monitoring and controlling transactions conducted with risky  countries,
  • Monitoring and controlling complex and extraordinary transactions,
  • Controlling, through  sampling  method,  whether    the  transactions  exceeding  a pre- determined limit are consistent with the customer profile,
  • Monitoring and controlling linked  transactions  which,  when   handled   together, are exceeding  the limit requiring  customer identification,
  • Controlling  completing   and   updating   the   information   and    documents   about  the customer which have to be kept in electronic media or in writing  and the compulsory  information which have to be included in electronic transfer  messages,
  • Monitoring whether a transaction   conducted   by the  customer  is  consistent  with the  information  about  the  customer's   business,   risk   profile   and    fund resources   on   a permanent  basis throughout the term of the business  relationship;
  • Controlling transactions conducted by using systems   which  enable  non-face-to- face transactions,
  • Risk-based control  of newly introduced products and services which may be exposed to abuse due to technological developments.
 Activities  falling  within  this   scope  are  executed   by  the    Compliance   Department. The Compliance  Department may have recourse  to the Bank’s other departments when necessary.


The purpose of the company’s training policy on AML/CTF  is to ensure the compliance with the Law and other arrangements issued as per the Law, to develop a corporate  culture by increasing the sense of responsibility of the personnel  with respect to the Bank's policies, procedures  and  risk-based   approaches  and  to  update  the  personnel’s knowledge. 

The training activities  related to the prevention of money laundering and financing of terrorism will be carried out in accordance with the size, business volume and the changing conditions of the Bank.

Training activities will be carried out under the supervision and coordination of the Compliance Officer. It is essential to conduct the training activities  under the yearly training program, prepared  to cover the subjects  given below. The training program will be prepared by the Compliance Officer with the contribution of the relevant  units. The effective performance of the implementation will be supervised by the Compliance Officer. 

Training activities will be reviewed according to scaling  and evaluation results,  with the participation of the relevant  units, and repeated  regularly. 

In a manner  to ensure training  activities to be performed in the whole institution; training  methods such as  organizing seminars and panels, creating workshops, use of  visual and audio materials in training activities, training programs supported by employee computers over internet, intranet or extranet  will be used as much as possible.

The company shall provide  all personnel with the necessary training  about  AML/CTF. Priority  of training is given to personnel who directly  deal with the customer.  It  is essential to train the new employees about  the subject during the orientation period. Trainings include classroom, on-the-job and on-line  training methods. Classroom and on-the-job trainings  are delivered by trainers who are designated by the Bank.  It is imperative  to attend to e-learning courses.

Trainings to be  provided  by the  company  to  the  personnel include  but  are  not  limited to the following  subjects: 

  • Concepts of money laundering and terrorist financing,
  • Stages and methods  of money laundering and case studies  about the subject,
  • Legislation on AML/CTF
  • Areas of risk,
  • Corporate policy  and procedures,
  • International regulations on AML/CTF
  • Know Your Customer procedures,
  • Suspicious Transaction Reporting  procedures,
  • Obligation of retaining and submitting,
  • Obligation of providing  information and documents,
  • Sanctions in violation  of obligations

The activities falling  within this scope are executed  by the Compliance Department and the Training  Department under the supervision and coordination of the Compliance Officer.


The purpose of internal audit is to give assurance to the   Board of Directors  regarding the effectiveness and adequacy  of  the   whole  Compliance  Program.  The  Bank procures that corporate  policies and procedures are reviewed and inspected  annually by using a risk-based approach  in order to determine whether risk management, monitoring and control activities as well as training  activities are adequate  and effective, whether the risk policy is adequate and effective, and whether transactions  are  conducted   in accordance with the Law and other  arrangements  issued  as  per  the  Law  and  the corporate policies  and procedures.

Within the scope of internal  audit activities; 

  • Defects, faults and abuses that are   discovered   as   a   result   of   internal   audits   as well as opinions  and recommendations to prevent their recurrence are reported to the Board of Directors.
  • Deficiencies discovered  in  the  course   of   monitoring  and  control   studies  and risky customers, services and   transactions  are  included  in  the  scope  of  the audit  when  determining the scope of the audit.
  • When determining the units and transactions to be audited,  care is exercised  to audit the number of units and transactions that are representative of the whole transactions conducted  at the Bank in terms of quantity  and nature.

Activities falling within this scope are executed  by the Board of Inspectors.