Compliance

CAC Bank adopts a comprehensive compliance framework designed to ensure adherence to applicable laws, regulatory instructions, and sound banking practices. This framework supports integrity, transparency, customer protection, and the prevention of money laundering, terrorism financing, sanctions violations, fraud, bribery, corruption, and other financial crimes.

Compliance and Anti-Money Laundering Committee

The Bank maintains a dedicated governance structure for compliance and anti-money laundering matters. The committee supports oversight of compliance risks, reviews relevant policies and procedures, follows up on implementation, and helps ensure that regulatory obligations are embedded across the Bank operations.

Sanctions Compliance Policy Statement

CAC Bank is committed to complying with applicable sanctions requirements and to screening customers, transactions, and relevant parties against local and international sanctions lists, in accordance with applicable laws, regulations, and approved internal procedures. The Bank does not knowingly enter into or continue relationships or transactions that violate sanctions obligations.

Customer Due Diligence and Enhanced Due Diligence (CDD / EDD)

CAC Bank applies customer identification and verification procedures before establishing banking relationships and throughout the relationship, whether through branches or approved alternative channels that rely on trusted automated verification methods. Relationships are also reviewed periodically or whenever unusual activity is identified.

Account-opening requirements and supporting documents are aligned with Central Bank of Yemen instructions and the Bank approved Anti-Money Laundering and Counter-Terrorism Financing policy.

For customers or transactions classified as high risk, the Bank applies enhanced due diligence procedures under a risk-based approach. These may include obtaining additional information and documents about the customer identity, business activity, sources of funds and wealth, the purpose of the account, and the consistency of transactions with that purpose. Additional control measures may also be applied when necessary, including field visits to customer locations where required.

Politically Exposed Persons (PEPs)

CAC Bank applies a specific policy for dealing with politically exposed persons, their family members, and close associates, in accordance with Central Bank of Yemen instructions. All PEPs are classified as high-risk customers and are subject to enhanced due diligence, including additional information gathering, closer transaction monitoring, and ongoing risk assessment. No banking relationship with a PEP is established or continued without senior management approval.

Reporting Suspicious Transactions

CAC Bank maintains a clear mechanism for reporting unusual or suspicious transactions. This is a fundamental part of the compliance framework and protects the Bank from money laundering, terrorism financing, and financial crime risks. All employees are required to promptly report any transaction that raises suspicion, appears inconsistent with the customer activity, or lacks a clear economic or legal purpose through approved internal channels.

The Compliance Department reviews reports in strict confidentiality, conducts the required analysis using a risk-based approach, and decides whether to request additional information, take preventive action, or submit an official report to the Financial Intelligence Unit (FIU) in accordance with applicable laws and instructions. The Bank applies clear controls and procedures to protect employees who report suspicious transactions in good faith from liability or unfair action.

Monitoring Unusual or Suspicious Transactions

CAC Bank applies a monitoring mechanism for unusual or suspicious transactions through automated control systems and analytical procedures designed to identify activities that may involve money laundering, terrorism financing, or other financial crime risks. Monitoring covers different types of financial and non-financial transactions carried out through the Bank.

The Bank applies risk-based indicators and scenarios that compare transactions against the customer profile, behavior, and business activity, allowing potential deviations or unjustified patterns to be identified, reviewed, and addressed in accordance with approved policies.

Funds Transfers

CAC Bank is committed to applying transparency and completeness standards in all payment messages and orders, in line with applicable laws, instructions, and international best practices related to AML/CFT. The Bank does not delete, alter, or conceal any information contained in funds transfer messages, whether related to the originator, beneficiary, or relevant parties.

All payment messages are screened against relevant international and local sanctions lists through the Bank approved systems and control procedures. Within the framework of local laws and regulations, the Bank also cooperates with other financial institutions and competent authorities when inquiries relating to funds transfers are received.

Anonymous or Fictitious Accounts

CAC Bank prohibits opening or maintaining anonymous, fictitious, or numbered accounts. The Bank does not establish any banking relationship unless the identity of the customer, whether a natural or legal person, has been fully verified using valid and approved official documents.

No account is opened and no banking service is provided until customer identification requirements and the verification of related information and data are completed in accordance with approved policies, procedures, and applicable regulatory instructions.

Employee Training

CAC Bank has a clear and approved plan for periodic training programs targeting all employees. These programs enhance awareness of customer identification policies and requirements, improve understanding of money laundering and terrorism financing risks, and introduce employees to relevant financial crime laws, regulations, and instructions.

The Bank role is not limited to delivering training programs. It also periodically evaluates their effectiveness and develops their content and delivery methods to keep pace with regulatory and supervisory developments and with best practices in banking awareness.

Training courses and programs provided by the Bank include, without limitation:

1. Anti-Money Laundering and Counter-Terrorism Financing.
2. International sanctions compliance.
3. AML/CFT governance fundamentals.
4. Financial fraud prevention.
5. Suspicion indicators and reporting procedures.
6. Trade-based money laundering.
7. Due diligence and account-opening procedures.
8. Duties of liaison officers.

Professional Certifications and Development of Compliance Staff

CAC Bank is committed to qualifying and developing Compliance Department staff by supporting specialized professional certifications in compliance, AML/CFT, international sanctions, and financial crime. This enhances performance, strengthens the quality of controls and compliance, and aligns with international best practices.

These certifications include, for example:

1. Certified Anti-Money Laundering Specialist (CAMS)
2. Certified Global Sanctions Specialist (CGSS)
3. Certified Fraud Examiner (CFE)
4. Certified Compliance Manager (CCM)
5. Know Your Customer Specialist (KYCS)
6. Regulatory Compliance Specialist (RCS)
7. Sanctions Compliance Specialist (SCS)

Record Keeping

CAC Bank is committed to retaining all types of records, documents, and files related to its banking operations in accordance with the Anti-Money Laundering and Counter-Terrorism Financing Law, for a period of not less than five (5) years from the date the customer relationship ends or the transaction is executed.

The Bank retains customer records, transaction records, reports, and control procedures in accordance with approved banking practices and in a manner that allows them to be easily retrieved when needed, whether for internal business purposes or to enable competent regulators and internal or external auditors to review them upon request.

The Bank also maintains the confidentiality and integrity of records, whether kept in paper or electronic form, in accordance with approved archiving and information security policies.

Anti-Bribery and Anti-Corruption

CAC Bank is committed to applying effective measures to combat bribery and corruption, protect the Bank reputation, and promote integrity and transparency in all activities and dealings with customers, partners, and stakeholders.

Bribery and corruption risks are integrated into the Bank control and compliance framework, which includes risk-based monitoring of relevant activities and transactions.

All Bank employees are responsible for reporting any suspicions or practices that may involve bribery or corruption through approved reporting channels, with confidentiality and protection for whistleblowers ensured in accordance with approved Bank policies.

Foreign Account Tax Compliance Act (FATCA)

CAC Bank is committed to applying the requirements of the Foreign Account Tax Compliance Act (FATCA). The Bank identifies customers who meet US person indicators or related entity criteria, collects and verifies the required documents and data at the start of the banking relationship and throughout it, and submits the required reports and information exchange for accounts subject to FATCA through approved channels.