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AML Statement 

 

AML Statement 

 

U.S. legislation obliges U.S. Banks, U.S. brokers and dealers in securities to provide information about banks which they regularly do business with. 

 
AML Statement

AML Statement

U.S. legislation obliges U.S. Banks, U.S. brokers and dealers in securities to provide information about banks which they regularly do business with.

Sparkasse Nürnberg is pleased to provide the following information.

The undersigned financial institution, Sparkasse Nürnberg, hereby certifies as follows:

A. Physical Presence/Regulated Affiliate Status:

Sparkasse Nürnberg maintains a physical presence. That means: Sparkasse Nürnberg has a place of business at the following street address: Lorenzer Platz 12, 90402 Nürnberg, where Sparkasse Nürnberg employs one or more individuals on a full-time basis and maintains operating records related to its banking activities.The above address is in Germany, where Sparkasse Nürnberg is authorized to conduct banking business. Sparkasse Nürnberg is subject to inspection by Bundesanstalt für Finanzdienstleistungsaufsicht, Graurheindorfer Str. 108, 53117 Bonn, the banking authority that licensed Sparkasse Nürnberg to conduct banking business.

B. Indirect Use of Correspondent Accounts:

No Correspondent Account maintained by a Covered Financial Institution may be used to indirectly provide banking services to certain foreign banks. Sparkasse Nürnberg hereby certifies that it does not use any Correspondent Account with a Covered Financial Institution to indirectly provide banking services to any foreign bank that does not maintain a physical presence in any country and that is not a regulated affiliate.

C. Ownership Information:

Sparkasse Nürnberg has no owner(s) except as set forth below. For purposes of this Certification, owner means any person who, directly or indirectly, owns, controls, or has power to vote 25 percent or more of any class of voting securities or other voting interests of Sparkasse Nürnberg; or (b) controls in any manner the election of a majority of the directors (or individuals exercising similar functions) of Sparkasse Nürnberg. For purposes of this Certification, (i) person means any individual, bank, corporation, partnership, limited liability company or any other legal entity; (ii) voting securities or other voting interests means securities or other interests that entitle the holder to vote for or select directors (or individuals exercising similar functions); and (iii) members of the same family* shall be considered one person. *The same family means parent, spouses, children, siblings, uncles, aunts, grandparents, grandchildren, first cousins, stepchildren, stepsiblings, parents-in-law and spouses of any of the foregoing. In determining the ownership interest of the same family, any voting interest of any family member shall be taken into account.

Name: Zweckverband Sparkasse Nürnberg
Adresse: Lorenzer Platz 12
90402 Nürnberg
Germany

“Zweckverband Sparkasse Nürnberg” is the responsible body (Träger) of Sparkasse Nürnberg, a public sector savings bank. Members of the Zweckverband´s general assembly representcity of Nürnberg 25 members

Landkreis Nürnberger Land 13 members
city of Hersbruck 4 members
city of Lauf an der Pegnitz 4 members
city of Röthenbach an der Pegnitz 2 members
Markt Schnaittach2 members

Sparkasse Nürnberg
Lorenzer Platz 12
90402 Nürnberg
Germany

Nürnberg, 23. September 2020

Administrative Details

Name:

Sparkasse Nürnberg

(BaFin Reg. No. 100616)

founded in: Nuremberg, Germany
Registered Office: Lorenzer Platz 12
90402 Nürnberg
Deutschland
Business Area: city and district of Nuremberg
Is the bank publicly listed on a stock exchange? no
  Chairman: Dr. Matthias Everding  
The Board of Management: Members: Roland Burgis, Dr. Jonathan Daniel, Matthias Benk
Our principal business activities and services are as follows: Savings bank, universal and regional bank, corporate and private customers, mortgage lending, retail banking

Applicable laws

Is the bank subject to laws and regulations for the prevention of money laundering and the financing of terrorists?


Relevant laws and regulations:

EU regulations and directives

Act on the Prevention of Money Laundering ("Geldwäschegesetz – GWG")

Banking Act ("Kreditwesengesetz - KWG")

Foreign Trade  and Payments Act ("Außenwirtschaftsgesetz  - AWG")

Securities Trading Act ("Wertpapierhandelsgesetz – WPHG")

Regulations of BaFin ("Amtliche Verlautbarungen des BaFin")

Bavarian Savings BanksAct ("Sparkassengesetz  -  SpkG")

Yes

Regulatory Authority

Is our bank subject to the supervision of any regulatory authority?

Name of Regulator:
Bundesanstalt für Finanzdienstleistungsaufsicht (BaFin)
Graurheindorfer Str. 108
53117 Bonn
Germany

Yes

AML policy and practice

Does our institution have a written policy against money laundering and terrorist financing? Yes
Does this policy meet FATF standards? Yes

Is the policy applicable to the headquarters, all branches and subsidiaries, including foreign branches and offices? *

We verify the customers` identity on  the basis of reliable, independent documentary, data and information sources and we
retain all relevant documents and information relating to the customers' identity and transactions in accordance with the requirements of the regulatory authority.

*Sparkasse Nürnberg does not have any foreign branches and offices.

Yes
Does our bank have an independent audit and/or compliance review function to test the adequacy of policy and procedures? Yes

Operational area

Does our bank maintain a correspondent banking relationship to a shell bank or do business with a shell bank ( A shell bank is defined as a bank incorporated in a jurisdiction in which it has no physical presence and which is unaffiliated with a regulated financial group)? No
Does our institution have a policy prohibiting correspondent accounts/ relationships with shell banks? Yes
Does our institution have policies to reasonably ensure that we will not conduct transactions with or on behalf of shell banks through any of our accounts or products? Yes
Does our institution have policies to reasonably ensure that it only operates with correspondent banks that possess licences to operate in their countries of origin? Yes
Does our institution obtain sufficient information to gain an understanding of our correspondents' business, reputation and regulatory history? Yes
Are all new correspondent relationships approved by a Senior Manager? Yes
Does our bank offer "Payable Through Accounts" or any other accounts which can transact through nostro and vostro accounts? (Payable Through Accounts are a type of correspondent banking account which is subdivided by the foreign bank into sub-accounts, each in the name of one of the foreign bank' customers, thus giving foreign bank's customers direct access to the products of the first financial institution.) No
Does our bank maintain anonymous accounts, or numbered accounts for which we do not collect the full details of the beneficial owner? No
Does our bank monitor customer account databases for terrorist names? Yes
Does our institution require full details for outgoing wire transactions, i.e. sender and beneficiary names, address and account number in accordance with the requirements of the regulatory authority? Yes
Does our institution have any restrictions under our Banking Licence e.g. is our institution only limited to conducting business with non-residents or in non-local currencies? No

Risk management details

Has a compliance office been set up and is a compliance officer in charge of supervising and coordinating efforts against money laundering and terrorist financing as well as monitoring compliance?

Contact address:
Sparkasse Nürnberg
Geldwäschebeauftragter / AML Officer
Lorenzer Platz 12
90402 Nürnberg
Germany

Yes
Does our institution determine the appropriate level of enhanced and ongoing due diligence necessary for those categories of customers and transactions that we have reason to believe pose a heightened risk of money laundering and terrorist financing activities at or through our institution? Yes
Does our institution take steps to understand the normal and expected transactions of our customers based on our risk assessment of our customers? Yes
Has our institution implemented systems for the identification of all our customers at account opening, including verification of customer information from independent and reliable sources (e.g. name, street address, date of birth, number and type of valid official identification)? Yes
Does our institution have procedures to establish a record for each customer noting their respective identification documents and Know Your Customer Information collected at account opening? Yes

AML Training

Does our institution provide AML training to relevant employees that includes identification and reporting of transactions that must be reported to government authorities, examples of different forms of money laundering involving our products and services and internal policies to prevent money laundering? Yes
Does our institution retain records of our training sessions including attendance records and relevant training materials used? Yes
Does our institution have policies to communicate new AML related laws or changes to existing AML related policies or practices to relevant employees? Yes
Does our institution employ agents to carry out some of the functions of our institutions and if so does our institution provide AML training to relevant agents that includes identification and reporting of transactions that must be reported to government authorities, examples of different forms money laundering involving our institution's products and services and internal policies to prevent money laundering? Yes

Transaction monitoring

Does our institution have a monitoring program for suspicious or unusual activity that covers funds transfers and monetary instruments (such as travellers cheques, money orders, etc)? Yes
Does our institution filter payments against relevant sanctions lists? Yes

Reportable transactions and prevention and detection of transactions with illegally obtained funds

Does our institution have policies or practices for the identification and reporting of transactions that are required to be reported to the authorities? Yes
Does our institution have procedures to identify transactions structured to avoid large cash reporting requirements? Yes
Does our institution screen transactions for customers or transactions we deem to be of significantly heightened risk (which may include persons, entities or countries that are contained on lists issued by government/ international bodies) that special attention to such customers or transactions is necessary prior to completing any such transactions? Yes

Laws and guidelines

Does our bank respect the currently valid laws and internal guidelines for the prevention of money laundering and the financing of terrorists? Yes
Has our institution been involved in any regulatory or criminal enforcement actions resulting from violations of laws or regulations against money laundering and terrorist financing in the past 5 years? No

Nürnberg, 23. September 2020

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