AML AND Sanctions Disclosures

Scope and Supervision
 

Bank of China Limited (“BOC”) is organized under the laws of the People’s Republic of China and operates four federally licensed branches in the United States - New York (Midtown), Queens, Chicago, and Los Angeles (collectively, “BOC U.S.A.” or the “Bank”). The New York and Queens branches are Federal Deposit Insurance Corporation (“FDIC”) insured; the Chicago and Los Angeles branches are uninsured. All U.S. branches are licensed by, and subject to examination by, the Office of the Comptroller of the Currency (“OCC”). 
 

BSA/AML/CFT Statement
 

BOC U.S.A. is committed to complying with all applicable U.S. laws and regulations designed to combat money laundering, terrorist financing, sanctions evasions, fraud, and other illicit financial activities, including the Bank Secrecy Act (“BSA”) and its implementing regulations, as amended by the USA PATRIOT Act and the Anti-Money Laundering Act of 2020. To this end, the Bank has adopted and maintains a written, risk-based Anti-Money Laundering/Counter Financing of the Terrorists Compliance Program (“BSA/AML Program”), approved by the Bank’s Board of Directors (or equivalent governing body). 

The BSA/AML Program applies to all BOC U.S.A. branches and to all employees, contractors, and contingent workers. The BSA/AML Program is structured around the five regulatory pillars to ensure full compliance with 31 C.F.R. § 1020.210. It maintains a robust control environment, adheres to the “Three Lines of Defense” model, and includes the following core elements:
•    Internal controls commensurate with the Bank’s risk profile and activities;
•    A designated Chief BSA Officer with sufficient authority, independence, and resources to oversee day-to-day compliance, escalate issues, and report to senior management and the governing body;
•    Independent testing/audit performed periodically by qualified internal audit or external parties;
•    Ongoing, role-based training for personnel; and
•    Customer due diligence (CDD), including a Customer Identification Program (CIP), beneficial ownership identification, and verification for legal entity customers, where applicable, along with ongoing monitoring.  

Program execution includes risk assessment, suspicious activity monitoring and reporting, currency transaction reporting, and information sharing under Sections 314(a) and 314(b) of the USA PATRIOT Act.
 

Sanctions Statement
 

BOC U.S.A. is committed to complying with all applicable U.S. laws and regulations, including all economic and trade sanctions-related programs and regulations administered and enforced primarily by the U.S. Department of Treasury’s Office of Foreign Assets Control (“OFAC”). BOC U.S.A. is committed to conducting business in accordance with the highest ethical standards and in full compliance with both the letter and spirit of all applicable laws and regulations.
 

OFAC strongly encourages organizations subject to U.S. jurisdiction, foreign entities that conduct business in or with the U.S., U.S. persons, and those using U.S.-origin goods or services to employ a risk-based approach to sanctions compliance by developing, implementing, and routinely updating their respective sanctions compliance programs.  Accordingly, BOC U.S.A. takes steps to mitigate potential compliance, regulatory, and reputational risks associated with violations of sanctions laws and regulations, as well as the risk of exposure to sanctioned parties.
 

BOC U.S.A.’s sanctions compliance programs is intended to:
•    Ensure compliance with economic sanctions programs promulgated by the U.S. Government;
•    Promote personnel awareness and the detection and reporting of sanctions-related activity internally and, when required, to government authorities through identified escalation channels;
•    Help ensure that BOC U.S.A. and its staff conduct business in compliance with all applicable sanctions-related laws and regulations and provide services to customers in conformity with BOC U.S.A.’s risk appetite;
•    Promote strong governance and risk management throughout BOC U.S.A. to properly manage and mitigate sanctions compliance risks;
•    Provide BOC U.S.A. with sanctions-related guidance, training, standards, and expectations for implementation within the U.S.; and
•    Help ensure full cooperation with regulatory and law enforcement authorities in civil and criminal investigations, prosecutions, and forfeiture actions relating to sanctions violations.

Wolfsberg Questionnaire

Please click here for the BOC U.S.A.’s Questionnaire.

USA Patriot Act Certification 

Please click here for BOC Group’s Certification.