Anti-financial crime compliance

Money laundering and the financing of terrorism pose considerable sociopolitical risks. For this reason, the prevention of money laundering and the implementation of anti-money laundering measures have been defined as central compliance goals in our Integrity Code. With our core business and our global production and sale of vehicles, we and companies controlled by the Group are subject to the provisions of the German Money Laundering Act (GwG), which applies to “commercial sellers of goods.” As a result, we are required to implement Group-wide and thus worldwide measures to prevent and combat money laundering and the financing of terrorism (anti-money laundering — AML — and counter terrorist financing — CTF — policies).

An integrated Group-wide compliance approach has been implemented in the Anti-Financial Crime (AFC) department in order to link prevention of the circumvention of supranational and national sanctions with measures to prevent and combat money laundering, organized crime and other criminal economic activity and the financing of terrorism. This is important, as these risks can not only have a negative impact on society; they can also cause long-term damage to our reputation, as well as financial damage that can negatively affect our companies and our shareholders and stakeholders.

The organizational structure of the AFC specialist unit serves as the central Group organization for promoting compliance with the GwG across all divisions. This structure also brings together under one roof our two Centers of Competence for Preventing and Combating Money Laundering and the Financing of Terrorism (CoC AML) and the Center of Competence for Checks against Sanctions Lists (CoC CSL). The objective of the sanctions compliance process is to ensure the performance of systematic reviews to determine whether the names of affected natural or juridical persons or organizations can be found on any sanctions list around the globe (checks against sanctions lists — CSL). The review thus involves checking supranational sanctions lists such as those published by the United Nations (UN) and the European Union (EU), as well as national sanctions lists, in particular those published by the United States, that may be applicable in certain situations.

As required by law, such reviews are conducted for customers and business partners, for example in sales and procurement, as well as for employees and strategic cooperation partners. The provisions of data protection law are taken into account when such checks against sanctions lists are performed. Our integrated compliance approach aims to ensure that we can effectively prevent and combat money laundering and the financing of terrorism.

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