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Compliance Policy Statement For Preventing Laundering of Proceeds of Crime, Terrorist-Financing and Financing of Proliferation of Weapons of Mass Destruction

For the purpose of contributing to the national and international efforts for combating laundering of proceeds of crime, terrorist-financing, financing of proliferation of weapons of mass destruction and such other associated crimes and as part of our obligation to comply with the applicable regulations thereto, a compliance program has been established within the organization of ING Bank A.S. In respect of establishment of the compliance program;
The Law Nr.5549 on Prevention of Laundering of Proceeds of Crime and the applicable secondary regulations thereto, and 
The Law Nr.6415 on Prevention of Terrorist-Financing and the applicable secondary regulations thereto, and 
The Law Nr.7262 on Prevention of Financing of Proliferation of Weapons of Mass Destruction and the applicable secondary regulations thereto, and 
The Know Your Customer Policy in place at ING and the related group procedures drawn up in compliance with the international standards

have been taken into account. 

Being involved in the "Obliged Parties" in accordance with the applicable national regulations, our Bank is subject to the obligations, namely know your customer, suspicious transaction reporting, establishment of training - internal audit - control and risk management systems, establishment of a compliance program, provision of information on continuous basis, storage and submission, provision of information and documentation, and  electronic notification as part of the Law Nr.5549 on Prevention of Laundering of Proceeds of Crime.

Laundering of proceeds of crime and terrorist-financing may occur in various forms in various fields of activity. Risk-based approach enables measurement of the risks for any potential laundering of proceeds of crime as based on each field of activity, and determination of the criteria thereto, and implementation of appropriate methods for mitigating such risks, as well as the control of such risks. Accordingly, together with its subsidiaries, which are financial institutions situated in Türkiye and which constitute the financial group in accordance with the local regulations thereto, ING Bank A.S. has established a compliance program, which includes the following measures, for the purpose of preventing any activity intended for laundering proceeds of crime and terrorist-financing.  

Establishment of a corporate policy and procedures (by taking into account the matters as determined as part of the national risk assessment),  
Implementation of risk management activities; 
Implementation of monitoring and control activities; 
Designation of a compliance officer and establishment of the compliance unit, 
Implementation of training activities; 
Implementation of internal audit activities, 
Fulfillment of the reporting, record retention obligations, 
Know your customer (including the principles related to customer due diligence), 
Sharing the information with respect to the accounts and transactions within the financial group 

The responsibility for implementing the compliance program adequately, effectively and properly shall remain ultimately with the Board of Directors, and all of our staff members are obliged to comply with the requirements of such program. The corporate policies and procedures, involving the components of the compliance program, are reviewed periodically, and any and all updates thereto are announced to the staff members.