CIBC has adopted an Anti-Money Laundering and Anti-Terrorist Financing Policy ("Policy") to:
- Minimize the risk that CIBC or its employees inadvertently become involved in money laundering or terrorist financing activities;
- Help protect the safety, soundness and reputation of CIBC by reducing the likelihood that CIBC will be used as a vehicle for, or become a victim of, financial crime; and
- Help facilitate compliance with all applicable regulatory requirements relating to anti-money laundering ("AML") and anti-terrorist financing ("ATF") in each country in which CIBC operates
The Policy and related standards (covering such topics as Client Due Diligence ("CDD") (also referred to as "know your customer") and Politically Exposed Persons ("PEPs")), are applicable to all divisions of CIBC (including its foreign branches and offices) and its wholly-owned subsidiaries globally (collectively referred to as "CIBC"), and meet or exceed the AML/ATF regulatory standards in each country in which CIBC operates.
CIBC has implemented procedures to ensure that relevant regulatory obligations with respect to reporting of large cash transactions, electronic funds transfers and cross-border movements of cash and monetary instruments are met in each jurisdiction.
CIBC has appointed a Chief Anti-Money Laundering Officer ("CAMLO") who is responsible to senior management and the board of directors for establishing and maintaining CIBC's AML/ATF Program. The CAMLO has appointed a Regional AML Officer and a Regional Money Laundering Reporting Officer ("MLRO") in each geographic region in which CIBC operates. In addition, the executive responsible for each line of business must designate one employee within the business to be the Line of Business AML Officer, with primary oversight responsibility for AML/ATF compliance within that business.
All new employees are required to compete CIBC's AML/ATF training within thirty (30) days of commencing employment, and thereafter are required to complete AML/ATF refresher training in accordance with CIBC standards.
All CIBC employees worldwide are required to report any identified unusual transaction or activity to the appropriate CIBC AML Group. The AML Group will conduct an analysis to determine whether the information may indicate money laundering or terrorist financing, and requires submission of a report to the appropriate authority.
Regarding completion of the Wolfsberg Group Correspondent Banking Due Diligence Questionnaire