International Business Department

Name of our institution:

Sparkasse Krefeld, BaFin-Registration no. 100875

Administrative Details:

Place of incorporation:
Krefeld

Registered address:
Ostwall 155,
47798 Krefeld,
Germany

Principal Places of Business:
Our principal places of business are the City of Krefeld, Kreis Viersen and the City of Geldern

Is our institution publicly listed on a stock exchange?
No

Members of our board of directors:

Chairman:
Dr. Birgit Roos

Vice Chairman:
Lothar Birnbrich

Managing Directors:
Markus Kirschbaum
Siegfried Thomaßen

Vice Managing Directors:
Jochem Dohmen
Stefan Felder
Harald Schulze

We engage in the following major activities or provide these services:

Savings, universal and regional bank; commercial, private, mortgage and retail banking

Governing Laws:

Is our institution subject to laws and regulations against money laundering and terrorist financing?
Yes

Our relevant laws and regulations are mainly:
EU-regulations Geldwäschegesetz (GWG)
Kreditwesengesetz (KWG)
Außenwirtschaftsgesetz (AWG)
Wertpapierhandelsgesetz (WPHG)
BaFin-Verlautbarungen

Regulatory Authority:

Is our institution subject to the supervision of any regulatory authority?
Yes

Name of the authority:
Bundesanstalt für Finanzdienstleistungsaufsicht (BaFin)
Graurheindorfer Str. 108
53117 Bonn
Germany

Does our institution have a written policy against money laundering and terrorist financing?
Yes

Is the policy up to FATF standards?
Yes

Is the policy applicable to the headquarters, all branches and subsidiaries, including foreign branches and offices?
Yes

Does our institution employ agents to carry out some of the functions of our institutions and if so does our institution provide AML training to relevant agents which includes identification and reporting of transactions that must be reported to government authorities, examples of different forms money laundering involving our institution's products and services and internal policies to prevent money laundering?
No

We confirm that the policy and procedures have addressed to the following issues:
Verification of the true identity of customer and beneficial owner using reliable, independent sources of documents, data or information:
Yes

Retention of all relevant documents and information in respect of customer identity and transactions according to the regulatory authority requirements:
Yes

Mechanism to detect suspicious or abnormal transaction activities, and procedures for reporting them: YesStaff training program:
Yes

Independent audit and/ or compliance review function to test the adequacy of policy and procedures:
Yes

Operations:
Does our institution maintain any correspondent institution relationship or conduct business with any shell bank?
No

Does our institution allow direct use of the correspondent account by third parties (Payable-through Account)?
No

Does our institution have any anonymous accounts?
No

Does our institution update our customer profile on a regular basis?
Yes

Risk Management Details:
Are there a compliance office set up for and a compliance officer in charge of supervising and coordinating efforts against money laundering and terrorist financing as well as monitoring compliance?
Yes

Name and contact details of the Money Laundering Officer:

Sparkasse Krefeld
Marc Stränger
Ostwall 155
47798 Krefeld
Germany

Compliance Status:
Does our institution presently comply with laws and its internal policy against money laundering and terrorist financing?
Yes

Has our institution been involved in any regulatory or criminal enforcement actions resulting from violations of laws or regulations against money laundering and terrorist financing in the past 5 years?
No

Krefeld, 1st October 2009