Compliance

Compliance

Anti-Bribery Policy Statement

Golomt Bank is committed to applying the highest standards of ethical conduct in its business activities. We take a zero tolerance approach to bribery and corruption and are committed to acting professionally fairly and with integrity in all our business dealings and relationships.

The purpose of this policy statement is that all business activities of the Bank is free from bribes or corruption; internal rules and regulations are in compliance with the content and purpose of this policy; being a financially responsible Bank that has a consolidated policy against corruption or bribe.

Management team, all employees, and customers of the Bank, prohibited strictly to offer and receive any bribes or to get involved in such corrupt activities.

Correctness and accuracy

Registration, financial and tax statements, and report of the Golomt Bank shall be accurate and transparent.

Gifts and entertainment

Expenses for purpose of offering, receiving, or promising cash, gifts, properties, entertainment or travels as bonus or reward for gaining preference shall be prohibited strictly.

Involvement in politics

Golomt Bank shall not directly or indirectly, be involved in any activities of political parties. The Bank is prohibited to make any payment to political party, politician and electoral candidate.

Charitable contributions and sponsorship

Golomt Bank is prohibited to grant charitable contributions and sponsorship in order to gain improper or undue business advantage.

Responsibility

All Bank employees are obliged to prevent, detect and report bribery and any other forms of corruption and the Bank shall inspect and determine any suspicious actions or breaches.

Resolving potential conflict of interest policy statement

  • All Bank employees shall avoid situations of any potential conflict of interest at their best. In other words, Bank employees are obliged to refuse to participate in any activities that may harm or influence the customers’ or the Bank’s interests, credibility, reliability or in conflict with the customers’ or Bank’s interest.

  • If a Bank employee who finds him/herself in an actual or potential conflict of interest he/she shall refuse to take part in any bank activities related to the issue in question.

  • If inescapable situation arises that gives rise to an inevitable conflict of interest, if not otherwise provided by the law, the Bank and its employees shall uphold the interest of the Bank customers at first.

Anti-Fraud policy statement

  • Golomt Bank and its employees are obliged to prevent, detect and report fraud such as deception, bribery, forgery, extortion, corruption, theft, conspiracy, embezzlement, misappropriation, misrepresentation and concealment of material facts.

  • Golomt Bank shall maintain a corporate culture of honesty and integrity among the staff, establishing controls and procedures designed to eliminate the potential circumstances of fraud and receive, investigate, report and recommend a remedial course of action in respect to suspected or voiced concerns of fraud or fraudulent behavior.



Whistleblowing policy statement

All staffs of the Golomt Bank have a duty to report activities that are not in line with Golomt Bank Charter, policies and procedures including Code of Ethics and Conduct such as:

  • Bribery and corruption
  • Conflict of interest
  • Bullying
  • Sexual or other harassment in workplace
  • Any other serious breach of ethical principles

Reports can be received through following channels:

  • E-mail: whistleblowing@golomtbank.com
  • Mobile: 85221646
  • Drop-in box: Located on the 1st floor of the Head office
  • Meet in person with the Director of Internal Audit Division or Compliance Department

The Bank exercises utmost care with regard to the confidentiality of a report and anonymity of the employee, within the limits as defined by applicable laws and regulations.

The Bank provides a confidence and reassurance to employees and other related parties to ensure that they will be protected from reprisals or victimization for their commitment to whistleblowing.

Please find AML Policy Statement from HERE.

Appointment of the nominated person

Head of Compliance Department is: Mrs. CHAMINCHIMEG TS.,
Tel: +976-70111646-1714
E-mail: chaminchimeg@golomtbank.com

The Bank’s AML Senior Specialist is Mrs. Munkhjargal N., CAMS
Tel: +976-70111646-1274
E-mail: munkhjargal@golomtbank.com

The Bank’s AML Senior Specialist is Mrs. Uyanga M., CAMS
Tel: +976-70111646-1274
E-mail: uyanga_mu@golomtbank.com

Establishment of internal procedures appropriate to the Money Laundering Regulation.

  • Know Your customer requirements

  • Reporting suspicious activity and transaction

  • Record-keeping

  • Internal control

  • Risk assessment and management

  • Compliance management

Internal training

Establishment of internal training requirements so all individuals within the Bank understand their responsibilities within the Bank’ policy and procedures and their wider responsibilities under the Mongolian Anti Money Laundering Law. To this end we will ensure all individuals within the Bank are trained at regular intervals for:

  • Awareness of the relevant legislation and any changes

  • Understanding of their roles and responsibilities under the Anti Money Laundering regime

  • Updates on particular threats and alerts for the firm or the profession

  • How to recognize potential suspicious activity

  • How to report suspicious activity

  • The Bank’s exposure to risk

  • The Bank’s client due diligence policies and procedures.

Record retention

We will retain the following records for five years after ceasing to act for a client

  • Client’s risk assessments

  • Client ‘s identity and verification

  • Client’s ongoing monitoring

  • Staff training

  • Internal reporting

  • External reporting

Reporting suspicious transactions

The Bank through the Compliance Department has established procedures for assessing internal suspicious activity reports and on the decision making process for external reporting. We have established procedures for making suspicious activity reports to the Financial Information Unit (FIU) of the Bank of Mongolia and for the secure retention and storage of internal and external reports.

Aiding law enforcement

The Bank through the Compliance Department has established procedures for aiding any law enforcement agencies who obtain money laundering investigation orders against our clients. These procedures relate to the collation and secure retention of the information required and systems to ensure that confidentiality of the client is maintained were necessary.

Staff commitment to the Bank’s policy and procedures

It is important that our staff understands the compliance culture and the roles and responsibilities placed upon them. Penalties imposed including fines and imprisonment can apply to individuals as well as the Bank.

  • ensure we understand the firms policy and procedures contained in this document, and ask relevant Officer if unsure

  • ensure that during the course of our work for the Bank we don’t turn a blind eye to the obvious. If we have doubts over the legitimacy of a transaction or event then we must follow procedures to discuss the situation or make an internal suspicious activity report. It is only by following these procedures we are protected from the possible penalties contained within the legislation

  • remember that we are not required to be an investigator that is the role of law enforcement, neither are we judge nor jury

  • remember that ‘tipping off’ is an offence under the legislation. We must not discuss what we may or may not report with the client and don’t make reports the topic of general conversation within the office.

Sanctions policy statement

Golomt Bank is committed to complying with relevant economic and trade sanctions laws and regulations of Mongolia, the United Nations (UN), as well as the European Union (EU), the United States (US) and the Her Majesty’s Treasury (UK).

FATCA

The Foreign Account Tax Compliance Act (FATCA) generally requires that foreign financial Institutions and certain other non-financial foreign entities report on the foreign assets held by their U.S. account holders or be subject to withholding on withholdable payments.

Golomt Bank is fully compliant with FATCA, therefore will require additional information from customers subject to FATCA requirements. Please find our W-8BEN-E form from HERE.

Wolfsberg questionnaire

The Wolfsberg Group is an association of thirteen global banks which aims to develop frameworks and guidance for the management of financial crime risks, particularly with respect to Know Your Customer, Anti-Money Laundering and Counter Terrorist Financing policies.

Golomt Bank commits to the Wolfsberg Group principles on Financial Crime Compliance.

Please find our Wolfsberg Financial Crime Compliance Questionnaire from HERE.

Patriot Act Certificate

This certificate certifying that Golomt Bank and its branches are not shell banks and do not serve shell banks.

Please find our USA Patriot Act Certificate from HERE.

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