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Luxembourg: Compliance/ Money laundering prevention

 The following contains information on the policies and activities of DZ PRIVATBANK S.A. (Registre de Commerce et des Sociétés: Luxembourg No. B 15579) that are in place to prevent the use of DZ PRIVATBANK S.A. for money laundering purposes and the funding of terrorism:

DZ PRIVATBANK S.A. is under the monitoring of the Luxembourg financial supervisory authority, the "Commission de Surveillance du Sector Financier" (CSSF). The banking licence issued by CSSF authorises DZ PRIVATBANK S.A. to offer banking services. By providing banking services, DZ PRIVATBANK S.A. is required to comply with Luxembourg laws and regulations that combat money laundering and the funding of terrorism.

DZ PRIVATBANK S.A. is in compliance with the policies and activities stipulated for the prevention of money laundering. These were given as Organisational Guidelines that were exclusively for internal use. The Organisational Guidelines of DZ PRIVATBANK S.A. adhere to the requirements of Luxembourg laws and regulations that combat money laundering and the funding of terrorism. This includes internal monitoring, activities and annual training courses for employees of DZ PRIVATBANK S.A.

The policies and activities stipulated are binding for all transactions carried out by DZ PRIVATBANK S.A., including any cross-border transactions. Compliance with the various policies and activities stipulated in the Organisational Guidelines is examined by an independent external auditing firm.

 The internal policies and activities contain the respective FATF/GAFI recommendations. Luxembourg is a member of the OECD organisation, FATF/GAFI (Financial Action Task Force on Money Laundering / Groupe d'action financière sur le blanchiment de capitaux). Luxembourg is also a member of the European Union (EU).

The beneficial owners of a corporate entitymust be identified in the same way as for an individual or legal entity as stipulated in accordance with the Organisational Guidelines of DZ PRIVATBANK S.A. Identification requirements shall apply for all parties/individuals involved.

The various policies and activities require the retention of the relevant KYC records. Following the end of the business relationship, DZ PRIVATBANK S.A. shall retain all records in relation to money laundering for at least five years.

Suspicious transactions are to be reported to the Financial Intelligence Unit (FIU) of the Luxembourg Public Prosecutor's Office. The activities require the prior approval of the FIU when implementing suspiscious transactions.

DZ PRIVATBANK S.A. does not offer correspondent banking services. DZ PRIVATBANK S.A. does not have account relationships with "shell banks".

Shareholder structure of DZ PRIVATBANK S.A.