Key Points of China Minsheng Bank’s Policies for Anti-Money Laundering and Counter-Terrorist Financing

I. General Provision
To effectively prevent money laundering and terrorist financing risks ("money laundering risks") and establish a sound money laundering risk management culture, China Minsheng Bank (the "Bank") has formulated the Key Points based on the laws, regulations and regulatory rules, such as the Anti-Money Laundering ("AML")Law of the People's Republic of China, the Counter-Terrorism Law of the People's Republic of China, the Administrative Measures on Customer Due Diligence and Preservation of Customer Identity Materials and Transaction Records by Financial Institutions, the Administrative Measures on the Reporting of Large-Value Transactions and Suspicious Transactions by Financial Institutions, the Administrative Measures on the Identification of Beneficial Owners of Customers by Financial Institutions, the Administrative Measures on AML Special Preventive Measures, as well as the Bank's actual circumstances.

The Key Points is applicable for China Minsheng Banking Corporation Limited and its subsidiaries in and outside the Chinese mainland.
II. Governance Structure and Responsibilities
The Bank continuously improves its group-wide money laundering risk management system, strengthens the deliberation mechanism of its AML Leading Group, and enhances the effectiveness of AML and counter-terrorist financing management. The Board of Directors and the Senior Management attach great importance to the allocation of  resources and duty performance assurance for AML. They oversee progress in key areas of AML, including the development of the bank-wide money laundering risk management mechanism, institutional money laundering risk assessments, reporting of suspicious transactions, sanction risk management, and the promotion of supporting due diligence model in centralized AML operations, and deliberate and make decisions on major AML matters.
III. Key Requirements
1. Customer Due Diligence (CDD)
Following the "Know Your Customer" principle, the Bank has established and continuously updates CDD management systems and mechanisms adapted to the Bank's circumstances, identifies and takes reasonable measures to verify the identities of customers and their beneficial owners, and takes appropriate CDD measures based on customers' characteristics, the nature of transaction activities and the relevant risk profile.
2. Ongoing Due Diligence
During the subsistence of the business relationship, the Bank continuously monitors and assesses the overall profiles and transaction activities of customers, understands the money laundering risks of customers, takes differentiated due diligence measures according to the relevant risk circumstances. and takes relevant money laundering risk control measures commensurate with the identified risks when necessary.
3. Customer Due Diligence in Specific Business Scenarios
For specific business scenarios, including cash-related business, safe deposit box services, merchant acquiring, agency services, remittance services, non-face-to-face business, third-party cooperation, and trust-related business, the Bank formulates more specific CDD management requirements to ensure the authenticity of customer identities and the rationality of transactions.
4. Terrorist Financing List Screening
In strict compliance with the requirements for AML special preventive measures, the Bank incorporates the following into the scope of name-list-based monitoring: the list of terrorist organizations and individuals recognized by the National Counter-Terrorism Leading Group and announced by its general office; the list of organizations and individuals involved in the targeted financial sanctions contained in the notices issued by the Ministry of Foreign Affairs on implementing United Nations Security Council resolutions, and the list of organizations and individuals recognized by the People's Bank of China, or jointly by relevant state authorities, that are bearing significant money laundry risks and might cause significant consequences if failing to be taken measures on. The Bank conducts list screening of all customers and business activities to prevent terrorist financing-related risks.
5. Enhanced Due Diligence for Politically Exposed Persons and High-Risk Countries or Regions
The Bank has clarified the requirements for identification criteria, approval procedures and enhanced due diligence for politically exposed persons, senior management of international organizations and the persons with specific relationships, and has established the mechanisms of dynamic monitoring, periodic review and ongoing monitoring for customers in high-risk countries or regions.
6. Record Keeping
The Bank takes appropriate measures to preserve and manage customer identity information and transaction records, in order to ensure that each transaction can be sufficiently reconstructed and traced, and is able to provide CDD information and transaction records to regulatory authorities and law enforcement authorities in accordance with applicable laws based on appropriate authorization, thereby facilitating the Bank's AML development, investigations and supervision. The Bank retains customer identity information for at least 10 years after the conclusion of a business relationship or the completion of an one-off financial service, and retains transaction records for at least 10 years after the completion of the transaction.
IV. Risk Assessment and Independent Assessment
In accordance with the Guidelines for the Self-Assessment of Money Laundering Risks of Financial Institutions, the Bank regularly conducts self-assessments on risks relating to money laundering, terrorist financing, and on the mitigation of non-proliferation-related targeted financial sanctions risks. The Bank fully implements the risk-based AML work principle, and makes full use of the results of its risk self-assessments to ensure that its allocation of AML resources, money laundering risk management strategies, risk management systems and processes are commensurate with its money laundering risk management profile.
V. Policy  Review and Update
The Bank's internal control policies and procedures for AML comprehensively cover the requirements of AML laws, regulations and regulatory rules, and remain aligned with the its strategic planning and actual business operations. When AML laws and regulations, regulatory requirements or the Bank's business development circumstances change, the Bank promptly revises its internal control policies for AML. All employees are required to keep abreast of policy updates in a timely manner, and ensure that their conducts comply with the Bank's internal policies.