Financial institutions must be able to identify and understand risks of money laundering and terrorist financing in order to apply preventive measures. Anti-Money Laundering (AML) and Counter Terrorist Financing (CTF) are prioritized focus areas at DANA.

DANA continually evaluates the strength and relevance of our existing policies, procedures and employee training. Money laundering and terrorism not only harm the public as a whole but can also damage the stability and reputation of the financial sectors. It is in our best interest to take all reasonable measures to prevent money laundering and terrorist financing.

DANA adheres to and complies with the utmost strictness of all KYC (Know Your Customer) and AML (Anti Money Laundering) compliance laws.

Since criminals require financial services in order to launder their proceeds and fund criminal activities, Know Your Customer (KYC) practices are important to us and the safety of the entire DANA client base.

DANA utilizes specific tools in order to detect suspicious transactions, such as transactions that are not in line with the customer's known profile. The detection of suspicious transactions triggers in-depth investigations of the customer's account by our Compliance Division. DANA has complete discretion to terminate an existing client relationship. DANA'S Compliance Department has the power to and will report suspicious transactions to the authorities.

No monies can be transferred into or accepted from countries considered as non co-operative without prior approval of DANA'S Compliance Department. Approval will only be given on the basis of proper documentation and thorough screening of the economic background and justification of the transaction.

In order to help governments track narcotic traffickers, terrorists and money laundering organizations DANA consults frequently updated international law enforcement compliance lists.

DANA does NOT accept Clients or Clients Funds from the following countries:

1. Burma (Myanmar)
2. Albania
3. Belarus
4. Bosnia & Herzegovena
5. Colombia
6. Democratic Republic of Congo
7. Cote D'ivoire
8. Cuba
9. Croatia
10. Iran
11. Iraq
12. Kosovo
13. Lebanon
14. Libya
15. Liberia
16. Macedonia
17. North Korea
18. Serbia & Montenegro
19. Sudan
20. Syria
21. Zimbabwe

Our Anti-Money Laundering and Counter Terrorist Financing Policy

 It is of great importance that financial institutions act to combat the risks of money laundering and assist governments in the identification of potential terrorist funding activities. Below are some of the policies we adhere to at DANA:

• DANA has adopted international policy standards on prevention of money laundering and countering terrorist financing that requires DANA'S head office, foreign branches and subsidiaries worldwide to implement and adhere to effective programs to comply with applicable laws. We strive that DANA'S Policy is appropriately applied throughout the company and duly supervised by DANA'S Risk Control Division;
• DANA'S Anti-Money Laundering Officer is dedicated to overseeing global policies, practices and procedures to prevent money laundering and the financing of terrorist activities.
• We have established appropriate controls, regulations and AML compliance procedures. DANA uses independent compliance, audit, risk management and legal functions to evaluate and ensure that our clients and businesses comply with applicable money laundering and terrorist financing laws, rules and regulations;
• DANA has established procedures and policies regarding Know Your Customer. We verify the customer's identity through documents, data or information obtained from a reliable and independent source (such as public records) and, where applicable, the beneficial owner. Furthermore DANA pays special attention to; - understanding the ownership and control structure of our customers, - obtaining information on the purpose and intended nature of business relationship, and - monitoring of business relationship, including scrutiny of transactions to ensure consistency about purpose, legitimacy and intended nature of business relationship.
• If a customer's reasons for a transaction/activity are not clear or understandable DANA takes measures in order to prevent money laundering or terrorist financing.
• We have developed and continue to update regulatory framework and procedures that meet or exceed applicable legal and regulatory requirements, and continuously educate our employees;
• We have established processes that match customer's relevant information against suspect terrorist and money laundering entities or individuals identified by government agencies (such as EU's and the USA Patriot Act's sanction list);
• Furthermore we co-operate with law enforcement and regulatory agencies worldwide;
• We have developed procedures that monitor transactions for the purpose of identifying suspicious activities;
• DANA regulations do not allow us to conduct business with banks without physical presence in the country of incorporation (shell banks);
• DANA does not allow direct use of correspondent accounts by third parties (payable through account) to transact business on their own behalf; and
• DANA does not allow anonymous accounts.

DANA continuously updates its regulatory framework and procedures, systems and technology, and we educate our staff to assure that we are well-equipped to combat money laundering and other financial crimes in order to assist governments in the war on terrorism. All this is done in accordance with national legislation and international recognized standards and regulations. We are fully committed to the prevention of the use of DANA'S products and services by those who abuse them.