SBFP Bank, in order to avoid the inadvertent use of its financial Group to cover the illegal origin of funds, and in order to fulfil the legal obligations to the extent necessary, has specific policies on prevention of money or securities laundering and financing of terrorist activities.

SBFP Bank prevention policy on funds laundering and terrorism financing is based on the following points:

• Identification and knowledge of our clients and their professional and economic activities.
• Constant follow-up of operations and business relations with our clients.
• Existence of an internal control and communication body.
• Implementation of internal procedures written with specific roles and profiles.
• Spread of prevention culture to all SBFP Bank staff through specific training activities and regular reminders.
• Communication with the relevant authorities according to the procedure that the regulatory body has established.

Money laundering prevention policy

Money laundering is the act of converting or transmitting money, goods or securities that come from any criminal activity which results in a prison sentence of over 6 months, or any crime related to prostitution, intellectual and industrial property, usage of privileged information, market manipulation, human trafficking for labour exploitation, illegal trafficking of toxic drugs, environment and natural resources, unlawful associations, extortion or illegal levies, corruption and influence peddling or document falsification, knowing its origin, with the purpose of hiding or concealing its illicit origin or helping any person that may have participated in the crime to escape the legal consequences of their acts.

Prevention of funds laundering and financing of terrorism:

• Act on international cooperation in criminal matters and prevention of the laundering of money or securities constituting the proceeds of international crime, from 29^th December 2000.
• 28/2008 Act, from December 11^th, on the modification of the Act on international cooperation in criminal matters and prevention of the laundering of money or securities constituting the proceeds of international crime, from 29^th December 2000.
• 4/2011 Act, from May 25^th, on the modification of the Act on international cooperation in criminal matters and prevention of the laundering of money or securities constituting the proceeds of international crime and against the financing of terrorism, from 29^th December 2000.
• 20/2013 Act, from October 10^th, on the modification of the Act on international cooperation in criminal matters and prevention of the laundering of money or securities constituting the proceeds of international crime and against the financing of terrorism, from 29^th December 2000.
• 4/2014 Act, from March 27^th, on the modification of the Act on international cooperation in criminal matters and prevention of the laundering of money or securities constituting the proceeds of international crime and against the financing of terrorism, from 29^th December 2000.
• 2/2015 Act, from January 15^th, on the modification of the Act on international cooperation in criminal matters and prevention of the laundering of money or securities constituting the proceeds of international crime and against the financing of terrorism, from 29^th December 2000.
• 11/2015 Act, from July 16^th, on the modification of the Act on international cooperation in criminal matters and prevention of the laundering of money or securities constituting the proceeds of international crime and against the financing of terrorism, from 29^th December 2000.
• Decree of 13^th May 2009 of approval of the Regulation to the Act on international cooperation in criminal matters and prevention of the laundering of money or securities constituting the proceeds of international crime and against the financing of terrorism.
• Decree of 18^th May 2011 of modification to the Act on international cooperation in criminal matters and prevention of the laundering of money or securities constituting the proceeds of international crime and against the financing of terrorism, approved by the Decree of 13^th May 2009.
• Decree of 20^th November 2013 of modification to the Act on international cooperation in criminal matters and prevention of the laundering of money or securities constituting the proceeds of international crime and against the financing of terrorism, approved by the Decree of 13^th May 2009.