Anti-Money Laundering and Terrorism Financing Mechanism

Anti-Money Laundering and Terrorism Financing Mechanism

You will find hereunder the questionnaire relating to Anti-Money Laundering and Terrorism Financing Mechanism.

FATCA Regulation

FATCA Regulation

The Foreign Account Tax Compliance Act (“FATCA”) is a U.S. law whose objective is to combat tax evasion by U.S tax payers. The Internal Revenue Service (“IRS” – U.S. tax authorities) has set up a framework to collect on a yearly basis from non-U.S. financial institutions information relating to foreign income and assets held by U.S. taxpayers outside the United States.

Starting 1st July 2014 financial institutions such as banks, life insurance companies, asset management companies, custodians, etc. will have to put in place procedures to identify their U.S. clients.

Since the year 2015, the financial institutions will start reporting to the U.S. tax authorities the identity and the tax identification number of their U.S. clients as well as their accounts’ balance as of 12/31/2014.

In order to facilitate the implementation of FATCA a large number of countries, including France, have negotiated intergovernmental agreements with the USA.

On 14 November 2013, the Government of France signed an Agreement with the Government of the United States (“IGA Agreement”) in accordance with the Franco-American Tax Convention for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion and Avoidance And authorizing the exchange of information for tax purposes, including automatically.

You will find enclosed the Form W-8BEN-E of CAFFIL.

Deontological code

As part of its CSR initiative, Sfil is updating its Code of Ethics and Ethics. This document now includes a code of conduct on anti-corruption, in correlation with the 10th Sustainable Development Goal (SDG) of the UN Global Compact to which Sfil acceded in 2018 and which the Bank has identified as a priority – among 8 others.

This new code is composed of four components: an “ethics in everyday life” component, a “relations with third parties” component, a “protection and reputation of the Sfil Group” component and a “financial security” component. It also incorporates a code of conduct on anti-corruption.

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Whistle-blower

Sfil undertakes in the context of its activities to respect and ensure that its Employees comply with all national and international laws and regulations that apply to it. In this context, Sfil set up an internal alert system in 2015 to strengthen the ethical approach and accountability of each employee, so that everyone is an actor in risk prevention. This system makes it possible to report any breach, particularly in the ethical, financial, anti-fraud and corruption fields, protection of personal data.

To this end, Sfil provides a dedicated and secure external platform (Signalement.net).  It allows reports that can be anonymous and secure exchanges in accordance with the ethical rules and legal provisions in force.  The platform can be used by external or occasional internal collaborators as well as by external persons (subcontractor, suppliers, former collaborator .. .). It guarantees the protection of personal data as well as strict confidentiality of the author of the report and the information transmitted. It is accessible via the internet at any time. Link to the platform