The information contained in this Certification is sought pursuant to Sections 5318(j) and 5318(k) of Title 31 of the United States Code, as addes by sections 313 and 319(b) of the USA PATRIOT ACT of 2001 (Public Law 107-56).
Landesbank Baden-Württemberg, a public sector bank, is fully answerable to the German supervisory authorities.
In Germany the legislative body as well as the supervisory authorities have set high standards to prevent money laundering, terrorism and organized criminal activities. LBBW has carefully incorporated these standards and developed extensive anti-money-laundering and anti-terrorist-financing-policies and -procedures. The relevant procedure manuals define at high level the policies and principles for managing the risks of involvement of such illegal activities. They provide the bases to further develop specific policies and operational procedures within each business line, and support their implementation. Furthermore, they support the foreign offices to meet group wide standards.
All international branches and subsidiaries are required to meet LBBW’s stringent standards and must also comply with all applicable local laws and regulations of each jurisdiction. LBBW is supervised by the banks money-laundering officer who is responsible for ensuring LBBW is in compliance with money laundering deterrence and detection procedures. These procedures include the ongoing monitoring of business relationships to ensure that the transactions being conducted are consistent with the business and risk profile, including where necessary the source of funds. Suspicious transactions are reported to the Financial Intelligence Unit (FIU).
All staff are regularly required to read and acknowledge the general instructions on money laundering. The guidelines require that staff be alert to and report any illegal, suspicious or unusual activities.
All staff are required to complete a group-wide technology-based Anti-Money-Laundering training programme customized which is tailored to job-specific tasks according to job-responsibilities, line of business and legal jurisdiction.
The Federal Republic of Germany also is a member of the Financial Action Task Force on Money Laundering. LBBW complies with the standards of the Financial Action Task Force (FATF) as well as with the Wolfsberg Anti-Money Laundering Principles.
For further confirmations, please contact the Bundesanstalt für Finanzdienstleistungsaufsicht ( www.BAFIN.de ), Grauheindorfer Straße 108, 53117 Bonn.
The LBBW's Annual Report and our completed PATRIOT Act Certification you can find here: