Customer Relationship Monitoring
In keeping with the Act on Prevention of Money Laundering and Terrorist Financing, within the framework of implementing due diligence measures, the Bank is obligated to apply the measure of continuous customer relationship monitoring. In accordance with the Act, the Bank is obligated to monitor business activities of every customer by applying the following measures:
- follow and check compliance of customer’s business operations against the anticipated nature and purpose of a business relationship and transaction,
- monitor and control the compliance of the source of funds with the anticipated source of funds that the customer stated when establishing the business relationship and for transactions,
- follow and check compliance of customer’s business operations with their usual scope of business operations,
- regularly monitor and control the collected documents and personal information of the customer and whether the customer has become or stopped being a politically exposed person.
Personal Data Processing
Periodic refreshing of personal information in the Bank’s records is necessary for uninterrupted business and maintenance of the mutual business relationship. Mandatory personal information that the Bank is obligated to record are as follows:
- identity data (information contained in personal identification document such as an ID card or passport),
- information on purpose and anticipated nature of a business relationship or a transaction.
The Bank collects and processes the mentioned information solely to the effect of preventing money laundering and terrorist financing, and such personal data processing, pursuant to and in compliance with the Act on Prevention of Money Laundering and Terrorist Financing, is considered a matter of public interest in compliance with the Regulation (EU) 2016/679 of European Parliament and Council.
Customers who are unable to visit the nearest Bank branch (based on the Bank's notification of the legal obligation to update personal data) may fulfil their obligation in one of the following ways. All proposed identification methods constitute a valid identification and upon receipt of the properly completed documentation, the Bank will update the personal data in its database.
a) through RBA Internet banking – customers who use RBA Internet banking can send a completed KYC Questionnaire for clients – natural persons (an editable Questionnaire for clients – natural persons is enclosed to the Bank's notification to customers) and a scan of a valid ID document through an authorized message.
b) through identification by the competent authority – customers can request the identification and certification of a copy of the identification document exclusively from the competent authority of the country where they are currently staying.
The competent authority is a notary public or a foreign diplomatic mission in Croatia, or the competent court or state administration body, a notary public and a diplomatic mission of the Republic of Croatia in foreign countries abroad. In addition to carrying out identification and certification of copies of the identification documents, customers are also required to complete the Questionnaire for clients – natural persons, which is provided to them together with the Bank's notification. All documents must be sent by post to the following address:
RAIFFEISENBANK AUSTRIA D.D.
OPERATIVNO POSLOVANJE - Podrška računima i servisima
SR NJEMAČKE 2
c) by a special power of attorney – clients can give a special power of attorney to update personal data and complete the necessary documents (Questionnaire for clients – natural persons) to any third person with active legal capacity, who will perform all necessary actions in the Bank's branch office upon presenting such power of attorney. The customer's signature on this special power of attorney must be notarized. Exceptionally, notarization of a signature on a special power of attorney is not required if the customer gives authorization for performance of this special action to the person who already has power of attorney to manage funds in the client's payment account or term deposit in the Bank. In addition to the original of the special power of attorney, the agent must also present the original or a certified copy of the customer's identification document at the branch.
The client's contact details cannot be updated with a special power of attorney.
The ordinary power of attorney for managing funds in the account is not recognized as a document which authorizes the agent to update the client's personal data.
d) by e-mail sent from the e-mail address recorded in the Bank's database – customers who previously updated the their e-mail address in the Bank's database by any method set out in their contract (personally in the branch, via IB or by a phone call to the Bank's Contact Center) may use that e-mail address to send a completed and signed Questionnaire for clients – natural persons (an editable Questionnaire for clients – natural persons is provided to clients in an attachment to the Bank's e-mail notification) and a scan of the valid personal identification document. These documents should be sent to the e-mail address: firstname.lastname@example.org.
Exception: Non-residents are required to send a certified copy of the identification document, which means they must previously request the identification and certification of the copy of the identification document only from the competent authority of the country in which they are currently residing.