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.
The customers who are unable to visit a Bank branch nearest to them (pursuant to receiving the Bank’s notification on statutory obligation to update personal information), can fulfil their in one of the following ways:
a) Through RBA Internet Banking – The customers who use the RBA Internet Banking can send their filled AML (Anti-Money Laundering) questionnaire (an editable AML questionnaire is attached to the Bank’s notification to customers) and a scan of their valid personal ID document by an authenticated message. A message received through this channel is considered an accurate identification and the Bank will, on the basis of the received documents, perform update of the respective personal information in its system;
b) By identification on the part of a competent authority – The customers who are unable to visit a Bank branch nearest to them and who are also not users of the RBA Internet Banking can request that exclusively the competent authority of their current country of residence performs the identification and certification of the identification document copy.
The competent authority in Croatia is a public notary or a foreign diplomatic mission, and abroad it is the competent court or government administration body, a public notary and the diplomatic mission of the Republic of Croatia. In addition to performing the identification and certification of the identification document copy, customers are required to fill also the AML questionnaire, which is delivered as attachment to the notification. The customers are required to send all documentation by post to the following address:
RAIFFEISENBANK AUSTRIA D.D.
SR NJEMAČKE 2
REPUBLIC OF CROATIA
In this case, the Bank will accept identification by a third/authorised party and will update such personal information in its system;
c) By a special letter of attorney – The customers who are unable to visit a Bank branch nearest to them and who are also not users of the RBA Internet Banking can give their special letter of attorney for the special legal action of updating personal information and filling of the required documents (AML questionnaire) to any third person who will, after presenting such a letter of attorney, perform all required actions at a Bank branch. Considering that the special letter of attorney must be notarized, such an attorney can bring either the original identification document or a notarized photocopy of it. Regular letter of attorney for managing a particular product is not acceptable as a document pursuant to which such an attorney would have the right to update the respective consumer’s personal information in connection to such a product.