Compliance & Financial Security

Establishing a corpus of internal standards on compliance

In order to ensure compliance of its actions and control risks, Crédit Agricole Leasing & Factoring has adopted a body of internal reference documents on compliance, updated regularly.

Specifically, its goal is to establish measures for preventing conflicts of interest, of the compliance of Crédit Agricole Leasing & Factoring’s new products and activities, as well as personal data protection.
Crédit Agricole Leasing & Factoring also applies the Code of Ethics of the Crédit Agricole group.

These internal procedures illustrate Crédit Agricole Leasing & Factoring’s commitment to comply with the laws, regulations and good professional practices, to bring the best quality of service to its clientele.

Crédit Agricole Leasing & Factoring takes measures so that its international development is conducted in compliance with local regulations, and in particular on compliance - financial security. In practical terms, this action is expressed by the appointment within each subsidiary of a compliance manager and by applying internal compliance rules and procedures.

Continuing training of personnel

The training of personnel is one of the major concerns of Crédit Agricole Leasing & Factoring. As such, each worker is required to take training on Compliance - Financial Security.
This training is systematically offered to each new worker hired with regular follow-up sessions.
Moreover, each worker can freely access the intranet site on compliance where he will find practical information and answers to his questions on compliance and financial security, as well as all internal standards and procedures.

Implementing financial security measures

Crédit Agricole Leasing & Factoring, under the current legal and regulatory obligations, has set up dedicated measures:

• preventing money laundering and the financing of terrorism,
• complying with embargo measures and freezing of assets.

These measures integrate on the one hand obligations arising from international rules and recommendations, and on the other hand those falling under national law:

International obligations:

• the recommendations and proposals of the Financial Action Task Force (FATF), intending to prevent the use of the banking system for purposes of illegal money laundering, as well as those intended to prevent the financing of terrorism;
• the 3rd European Directive (2005/60/EC dated 26 October 2005) on the prevention of use of the financial system for purposes of money laundering and the financing of terrorism, aiming to coordinate the provisions of the member-states.

National obligations, compiled in the Monetary-Financial Code and on:

• being cautious when entering into new relationships (identification of clients) or in the course of relations, in particular for transaction occurring under unusually complex conditions or with no apparent economic rationale or lawful purpose;
• documenting and archiving of information;
• refraining from relations or transactions where the information obtained has not allowed for the legality; the declaration of suspicions to TRACFIN, an organisation connected to the Ministry of Economy and Finance.

The Financial Security cluster of Crédit Agricole Leasing & Factoring, which is an integral part of the compliance control measures, is responsible for setting up and monitoring these measures which are expressed by:

• defining the rules for entering into new relationships with and knowing clients (KYC: “Know Your Customer”),
• monitoring transactions during the course of relations,
• setting up dedicated tools,
• a specific training program on combating money laundering, fraud, and the financing of terrorism,
• treating anomalies or suspicious transactions and eventually declaring them to the national authorities.