Anti-Money Laundering and Combating the Financing of Terrorism
and Weapons of Mass Destruction Policy

Introduction

     Bangkok Life Assurance Public Company Limited and its subsidiaries (“the Company”) realize the importance of both domestic and international laws on anti-money laundering and combating the financing of terrorism and weapons of mass destruction (AML/CFT-WMD), which aim to prevent money laundering and financing of terrorism and weapons of mass destruction. Moreover, the Company is committed to preventing itself from being used as a tool or channel for money laundering or financing of terrorism and weapons of mass destruction. Therefore, the Board of Directors has established this policy.

Purpose

     To be an operational governance framework to prevent money laundering and financing of terrorism as per international standards in accordance with related laws regarding anti-money laundering and combating the financing of terrorism.

Scope

     This policy applies to the Company’s directors, employees, agents, brokers, and business partners.

Definition

     “Customer”

is defined as an individual, an entity, or a person with legal agreement who builds business relationship or makes transactions with the Company, such as life insurance customers, loan customers, and mutual fund customers.

     “Money laundering”

is defined as conversion of money or assets derived from illicit activities or illegal means to legally-obtained money or assets, or conversion of illegally-obtained money or assets to make them appear as though they are legitimately earned.

     “Transaction”

is defined as engagement into a juristic act, contract, or any interaction with another person, involving financial, commercial, or asset-related matters.

     “Terrorist act”

is defined as an act which constitutes an offense related to terrorism under the Penal Code, or an act which constitutes an offense within the scope of international conventions and treaties related to terrorism to which Thailand is a party or acceded, regardless of whether such act is committed within or outside the Kingdom.

     “Designated person”

is defined as a person, group, legal persons, or entity included, by a resolution or notification of the United Nations Security Council, on the list of people committing an act of terrorism or proliferation of weapon of mass destruction, which has been announced by the Office. It also includes a person, group, legal person, or entity who, by the Court’s consideration and order, is identified as a designated person under Counter-Terrorism and Proliferation of Weapon of Mass Destruction Financing Act B.E. 2559 (2016).

Policy Requirement

1. Risk Management for Money Laundering and Financing of Terrorism and Weapons of Mass Destruction

     The Company establishes measures to evaluate and manage the risks associated with money laundering and financing of terrorism and weapons of mass destruction in accordance with the laws and international standards as follows.

1. Organizational Risk Management
2. Customer Risk Management
3. Partner Risk Management

2. Customer Acceptance

     The Company establishes processes for approving or rejecting the establishment of business relationships or transactions customers, including customer identification, Know Your Customer (KYC) assessment, and verification of customer information, ultimate beneficial owners, and those related to the customer, as per the criteria specified by laws.

3. Internal Control Measures

     The Company establishes measures for appropriate internal controls tailored to internal risks and the size of the business.

4. Reporting Transactions to the AMLO

     The Company establishes criteria for reporting transactions in accordance with the anti-money laundering law and related ministerial regulations.

5. Maintenance of KYC Information, Customer Verification, and Transaction Reporting Information

     The Company establishes secure and dependable methods for maintaining customers’ data and documents related to KYC, transactions, and fact verification as well as transaction reporting. The data and documents are retained to be readily available for examination and used as evidence in accordance with the laws, and can be viewed or provided as required by the AMLO.

6. Processes to Ensure Compliance with Anti-Money Laundering and Combating the Financing of Terrorism and Weapons of Mass Destruction Laws

     The Company must verify information of customers, occasional transaction processors, partners, and those related to customers against the Sanction List before approving the establishment of of business relationships or transactions. This is to prevent itself from being used as a channel for money laundering and financing of terrorism and weapons of mass destruction by designated persons.

     If the Company discovers that a customer, occasional transaction processor, or partner is a designated person, it must reject or terminate the establishment of business relationship or transaction with that persons and take appropriate actions against them in accordance with criteria specified by laws.

7. Violation

     Violation of this policy is considered violation of the Company’s Code of Conduct. The violator may face punishment as prescribed by anti-money laundering and combating the financing of terrorism and weapons of mass destruction laws.

​Policy Review

     The Company shall regularly review and revise this policy or when there are material changes.