The Arab Petroleum Investments Corporation (APICORP) was established in accordance with a multilateral agreement between the governments of the ten member states of the Organization of Arab Petroleum Exporting Countries (OAPEC)1. The Gulf Cooperation Council (GCC) is a full Member of the Financial Action Task Force (FATF). As an FATF Member, the GCC is committed to implementing the Anti-Money Laundering (AML) and Counter-Terrorist Financing (CFT) measures agreed to by the FATF Members – in particular, the FATF Recommendations2.
With respect to our other member states, an inaugural Ministerial Meeting held in Manama, Bahrain on the 30th of November 2004, the Governments of 14 countries decided to establish MENAFATF as a FATF Style Regional Body (FSRB). It was agreed that the headquarter of this body will be in the Kingdom of Bahrain. The MENAFATF is voluntary and co-operative in nature and independent from any other international body or organisation; it was established by agreement between the governments of its members and is not based on an international treaty. It sets its own work, regulations, rules and procedures and co-operates with other international bodies, notably the FATF, to achieve its objectives3.
APICORP Policies & Practices
APICORP – Bahrain Branch is licensed by the Central Bank of Bahrain (CBB) and follows all relevant laws and regulations issued by the CBB. In addition, APICORP has in place the following framework at a group level:
- A comprehensive Compliance and AML/CFT Policies & Procedures Manual
- KYC Questionnaires
- Code of Conduct (includes our policy on anti-bribery and corruption)
- Compliance & AML screening system
- Comprehensive compliance checklist
Compliance & AML Policy
APICORP is committed to preventing the use of its operations, both domestic and abroad, for money laundering, terrorist financing and other criminal purposes. In its approach to combat money laundering and terrorist financing, APICORP is committed to adhering to all laws and regulations that are applicable in the Kingdom of Saudi Arabia, Kingdom of Bahrain, and other countries in which it operates. It is also committed to complying with international best practices, especially those endorsed by the FATF, Basel Committee on Banking Supervision, and Wolfsberg Group.
APICORP’s Compliance & AML Policy sets out the minimum standards which must be complied:
- The appointment and approval of the Compliance Officer, who has the responsibility for oversight of compliance with relevant regulations, rules and best practices;
- The appointment and approval of the Money Laundering Reporting Officer (MLRO), who has the responsibility for oversight of all AML activity within the corporation;
- Establishing and maintaining a thorough Customer Due Diligence, identification, verification and Know Your Customer (KYC) procedures. This includes an enhanced due diligence for high risk counterparties (i.e. Correspondent Banks, Politically Exposed Persons etc.);
- In accordance with CBB regulations and FATF recommendations, APICORP does not deal with and Shell Banks (banks that have no physical presence);
- Ongoing monitoring of counterparty activities and frequent counterparty reviews;
- Procedures for identifying and reporting Suspicious Transaction Reports (STRs) internally and/or to regulatory bodies (i.e. the CBB);
- Compliance & AML training and awareness to all relevant employees;
- Retention of records for the minimum prescribed periods as per local regulations;
- Appropriate reporting on Compliance/AML matters to senior management and the Board (if material).
Sanctions Compliance Policy
APICORP, or any of APICORP’s subsidiary, nor any of their respective directors or officers nor any agent, employee or affiliate of APICORP or APICORP’s subsidiaries: is a Restricted Party; has been engaged in any transaction, activity or conduct that could reasonably be expected to result in its being designated as a Restricted Party; or has received notice of or is aware of any claim, action, suit, proceeding or investigation against it with respect to Sanctions or by any Sanctions Authority.
APICORP’s Sanction Compliance Policy ensures that the Corporation complies with all applicable sanctions laws in every jurisdiction with which it may operate/trade.
- Screening customers/clients and transactions globally against the sanctions lists issued by the United Kingdom’s HM Treasury (HMT), the European Union, the United Nations, and the United States of America Department of the Treasury – Office of Foreign Assets Control (OFAC);
- Prohibiting business activity, including prohibitions on commencing or continuing customer relationships or providing products or services or facilitating transactions that APICORP believes may violate applicable sanctions laws or APICORP’s Sanctions Policy. This includes individuals or entities named on a sanctions list or activity, directly or indirectly, involving countries or territories subject to comprehensive sanctions;
- Restricting business activity involving, directly or indirectly, countries or persons subject to more selective or targeted sanctions programmes. These restrictions impact not only the types of products or services that APICORP may make available but also the types of transactions APICORP may process;
- Investigating all customer/client alerts or transactions that are flagged in APICORP’s screening systems. While APICORP seeks to investigate these alerts and transactions in a reasonable timeframe, compliance with applicable sanctions laws or APICORP’s Sanctions Policy may result in delays to the processing of customer transactions while additional due diligence is conducted and information obtained on the nature of the underlying transaction or the parties involved;
- Reporting breaches of sanctions laws to the relevant regulatory authority. This may include any attempt by a customer to evade sanctions laws;
- All relevant employees receive ongoing training on the Sanctions Compliance Policy.
APICORP has ceased any business relationship with the government of Syria or any other Syrian entity. It is adhering to the international sanctions against Syria imposed by UN and Arab league. Any inflow or outflow of funds to and from Syria is prohibited. There has been no Syrian representation at any General Assembly or at any Board Meeting since 2009.
All new staff (including temporary or contract staff who may be involved in customer business) undergo induction training and refresher training to ensure that they understand the Corporation’s approach to money laundering deterrence.
Staff in high-risk areas are required to receive appropriate training to enable them to understand the money laundering techniques which are likely to be used in their area, and to remind them of their personal responsibilities.
1 Kingdom of Saudi Arabia, United Arab Emirates, State of Kuwait, Libya, State of Qatar, Republic of Iraq, People’s Democratic Republic of Algeria, Kingdom of Bahrain, Arab Republic of Egypt and Syrian Arab Republic.
© 2018 APICORP – All information contained in this document is proprietary to APICORP. No part of this document may be photocopied, electronically transferred, modified, or reproduced in any manner without the prior written consent of the relevant authorities within APICORP.