Compliance and Ethics Culture
As an actor in the banking and financial market in Tunisia, TSB is committed to the correct implementation of applicable regulation and ethics for banking and financial activities. More specifically, it ensures that no entity within the bank is a non-compliance risk situation.
As a reminder, a “non-compliance risk” is defined as being the risk of a judicial, administrative or disciplinary sanction, of significant financial loss, or reputation loss, borne from non-compliance with provisions specific for banking and financial activities, whether they are legislative or regulatory, or are professional and ethical standards, or instructions by the executive body.
As a responsible bank, TSB specifically ensures :
- Respect of laws, regulations and ethical principles specific to banking activities and investment services carried out by the bank and respect rules of conduct and personal ethics of staff
- Awareness and training of all actors on preventing non-compliance risk and reputational risk
- Implementation of regulatory requirements namely due diligence in terms of AML/FT and techniques for tracking suspect transactions unfortunately
- The development of a compliance culture amongst staff, in accordance with existing regulations as well as professional best practices.
Anti-Money Laundering and Financing Terrorism
TSB gives the utmost importance to anti-money laundering, and fight against the funding of terrorism as well as the respect of international sanctions (asset freezing and embargoes).
The Compliance Control Department is in charge of :
- Implementing measures aimed at preventing money laundering and the funding of terrorism
- Ensuring compliance with international sanctions
By updating its procedures and tools, TSB takes into account new requirements of existing regulation in terms of anti-money laundering and the funding of terrorism.
Thus, our mechanism was strengthened in order to improve the quality of collected KYC (“Know Your Customer”) data, both at the time of entry into relationship as well as during the business relation (continued watch) and to extend these implemented vigilance measures. Thus, at the time of entry into relationship, the verifications required for customer identification are a first filter. This prevention is based on the knowledge of customers and of effective beneficiaries, supported by information research through specialized databases or lists. Throughout the business relationship, an adequate vigilance proportional to the identified risk level. As such, IT programs for customer profiling and detection of unusual operations are used to support TSB staff.
Fighting the funding of terrorism and the mechanism to respect international sanctions also involve constant screening of customer records, both at the time of entry into relationship and during the relationship, with sanctions lists as well as monitoring of international operations.
The global mechanism, both for anti-money laundering and the funding of terrorism, as well the respect of international sanctions, are in constant strengthening, in the framework of regulatory evolutions as well as risk assessment.
FATCA is a regulatory mechanism which concerns TSB and its customers
Context of the law
In order to facilitate the application of this law, intergovernmental agreements were negotiated with many countries including Tunisia, these countries agreed to transpose into their domestic legislation the reporting obligations of FATCA. As such, an intergovernmental agreement was signed on 13 May 2019 between the Tunisian government and the Government of the United States of America regarding the American FATCA law.
Application of the law by TSB
TSB has gone into compliance with this American FATCA law :
- by registering on the website of the Internal Revenue Service IRS, on 28/12/2014 under GIIN code n°5PZ7SZ.00000.LE.788.
- by setting up internal procedures in order to identify clients with tax residency in the US, and if necessary, to transmit to the American IRS, through the Ministry of Finance, the information on the account(s) held by these clients.