BCB Group is committed to respecting its legal and regulatory, ethical and social responsibilities to protect our clients, our people, our stakeholders and partners and to support regulatory and law enforcement authorities in economic crime prevention. It is the policy of BCB Group to conduct business with integrity and in an honest and ethical manner in all its business dealings and relationships, wherever it operates.

BCB Group operates a three-lines-of-defence model and has in place a comprehensive financial crime management framework, comprising policies, procedures, systems and controls to combat the risk of financial crime and continually strives to ensure that accounts held at BCB are not misused for the purpose of facilitating financial crime. On an annual basis, BCB Group regulated entities commission an independent assurance review of the effectiveness of its financial crime framework. 

BCB Group expects its own customers to operate in a manner that is consistent with BCB Group’s own compliance standards and risk appetites. We expect clients to conduct themselves with integrity, openness and full transparency and are required to demonstrate they have in place a robust financial crime risk framework.

Our Risk Appetite Statement (RAS) defines the boundaries within which we operate to protect our clients, our banking partners, and the integrity of the global financial system: –

 

    1. BCB has a zero tolerance approach to knowingly engaging in or facilitating financial crime. This zero tolerance applies to all activities by BCB staff or associated persons which amount to a breach of financial crime laws and regulations. While our risk appetite is zero tolerance, we acknowledge that the complete elimination of financial crime exposure is not always possible in practice. Our commitment is to never knowingly turn a blind eye to risks we become aware of, and to respond promptly and decisively once risks are identified and investigated.
    2. BCB maintains a zero risk appetite for certain high-risk sectors and activities. BCB will not enter into business relationships with entities or individuals actively involved in the following sectors, nor will it knowingly facilitate related transactions:
  • Unregulated or unlicensed money service businesses (MSBs). 
  • Shell Banks or Shell Companies lacking verifiable economic substance.
  • Illegal sale or distribution of recreational drugs; Human trafficking, modern slavery, and any other illegal activity.
  1. BCB has a zero risk appetite for servicing any clients established in prohibited risk jurisdictions or out-of-appetite risk jurisdictions. BCB has a zero risk appetite for handling transactions in prohibited risk jurisdictions or out-of-appetite risk jurisdictions. Prohibitive risk countries are those where BCB is prohibited from providing its products and services due to regulatory prohibitions or because they are subject to sanctions. BCB also maintains “out-of-appetite” risk countries where the BCB Board has determined present an unacceptable risk (but which are not legally restricted) and has therefore determined not to offer or provide its products and services. 
  2. BCB has a zero risk appetite for any involvement in facilitating deliberate or knowing participation (directly or indirectly through its clients) in activities which amount to a breach of financial crime laws and regulations in the countries in which we operate or that apply to our business, our operations and the transactions we undertake. This applies in particular to money laundering, terrorist financing and proliferation financing. 
  3. BCB has a zero risk appetite for doing business with any designated individuals, businesses or countries which are on applicable sanctions lists. BCB has a zero risk appetite for breaches of sanctions. This means BCB has a zero risk appetite for its direct clients or their transactions being confirmed to involve any designated individuals, businesses or countries which are on applicable sanctions lists. 

BCB Group maintains a zero risk appetite for all forms of (given or received) facilitation payments, bribery, or corruption in any jurisdiction, whether carried out by its own people or its associated persons. BCB maintains a zero tolerance for the criminal facilitation of tax evasion by any associated person

Country Onboarding Payments
Afghanistan Prohibited Prohibited
Albania High Risk High Risk
Algeria High Risk Prohibited
American Samoa High Risk High Risk
Angola Prohibited Prohibited
Anguilla High Risk Prohibited
Antigua & Barbuda High Risk Prohibited
Antilles High Risk High Risk
Argentina High Risk High Risk
Armenia High Risk High Risk
Aruba (cfr NL) High Risk High Risk
Azerbaijan High Risk High Risk
Bahamas High Risk High Risk
Bahrain High Risk High Risk
Bangladesh High Risk High Risk
Barbados High Risk Prohibited
Belarus Prohibited Prohibited
Belize High Risk High Risk
Benin High Risk High Risk
Bermuda High Risk High Risk
Bolivia High Risk Prohibited
Bosnia and Herzegovina High Risk High Risk
Botswana High Risk High Risk
Brazil High Risk High Risk
British Virgin Islands High Risk High Risk
Bulgaria High Risk Prohibited
Burkina Faso Prohibited Prohibited
Burundi Prohibited Prohibited
Cambodia Prohibited Prohibited
Cameroon High Risk Prohibited
Cayman Islands High Risk High Risk
Central African Republic Prohibited Prohibited
Chad High Risk High Risk
Colombia High Risk High Risk
Comoros High Risk High Risk
Cook Islands High Risk High Risk
Costa Rica High Risk High Risk
Cote D’ivoire High Risk Prohibited
Croatia High Risk High Risk
Cuba Prohibited Prohibited
Curaçao High Risk High Risk
Cyprus High Risk High Risk
Democratic People’s Republic of Korea Prohibited Prohibited
Democratic Republic of the Congo Prohibited Prohibited
Djibouti High Risk High Risk
Dominica High Risk High Risk
Dominican Republic High Risk High Risk
Ecuador High Risk High Risk
Equatorial Guinea High Risk High Risk
Eritrea Prohibited Prohibited
Eswatini Prohibited Prohibited
Ethiopia Prohibited Prohibited
Fiji High Risk High Risk
Gabon Prohibited Prohibited
Gambia High Risk High Risk
Ghana High Risk Prohibited
Gibraltar High Risk High Risk
Grenada High Risk High Risk
Guam High Risk High Risk
Guatemala High Risk High Risk
Guernsey High Risk High Risk
Guinea High Risk High Risk
Guinea-Bissau High Risk High Risk
Guyana High Risk High Risk
Haiti Prohibited Prohibited
Honduras High Risk High Risk
Iran Prohibited Prohibited
Iraq Prohibited Prohibited
Isle of Man High Risk High Risk
Jamaica High Risk High Risk
Jersey High Risk High Risk
Jordan High Risk High Risk
Kazakhstan High Risk High Risk
Kenya High Risk Prohibited
Kiribati High Risk High Risk
Kyrgyzstan High Risk High Risk
Laos Prohibited Prohibited
Lebanon Prohibited Prohibited
Lesotho High Risk High Risk
Liberia High Risk High Risk
Libya Prohibited Prohibited
Macau High Risk High Risk
Madagascar High Risk High Risk
Maldives High Risk High Risk
Mali Prohibited Prohibited
Marshall Islands High Risk High Risk
Mauritania High Risk High Risk
Mauritius High Risk High Risk
Mexico High Risk High Risk
Micronesia High Risk High Risk
Moldova High Risk High Risk
Monaco High Risk Prohibited
Mongolia Prohibited Prohibited
Montenegro High Risk High Risk
Montserrat High Risk High Risk
Morocco High Risk Prohibited
Mozambique Prohibited Prohibited
Myanmar Prohibited Prohibited
Namibia High Risk Prohibited
Nauru High Risk High Risk
Nepal High Risk Prohibited
Nicaragua Prohibited Prohibited
Niger Prohibited Prohibited
Nigeria Prohibited Prohibited
Niue High Risk High Risk
Pakistan High Risk Prohibited
Palau High Risk High Risk
Palestine Prohibited Prohibited
Panama High Risk Prohibited
Papua New Guinea High Risk High Risk
Paraguay High Risk High Risk
People’s Republic of China Prohibited Prohibited
Peru High Risk High Risk
Philippines High Risk Prohibited
Puerto Rico High Risk High Risk
Russia Prohibited Prohibited
Rwanda High Risk High Risk
Saint Kitts and Nevis High Risk High Risk
Saint Lucia High Risk High Risk
Saint Vincent and the Grenadines High Risk High Risk
Samoa High Risk High Risk
Sao Tome and Principe High Risk High Risk
Senegal High Risk Prohibited
Serbia High Risk High Risk
Seychelles High Risk High Risk
Sierra Leone Prohibited Prohibited
Solomon Islands High Risk High Risk
Somalia Prohibited Prohibited
South Africa High Risk Prohibited
South Sudan Prohibited Prohibited
Sri Lanka High Risk High Risk
Sudan Prohibited Prohibited
Suriname High Risk High Risk
Syria Prohibited Prohibited
Tajikistan High Risk High Risk
Tanzania High Risk Prohibited
Timor-Leste High Risk High Risk
Togo High Risk High Risk
Tonga High Risk High Risk
Trinidad and Tobago High Risk High Risk
Tunisia High Risk High Risk
Turkey High Risk High Risk
Turkmenistan High Risk High Risk
Turks and Caicos Islands High Risk High Risk
Tuvalu High Risk High Risk
Uganda Prohibited Prohibited
Ukraine High Risk Prohibited
US Virgin Islands High Risk Prohibited
Uzbekistan High Risk High Risk
Vanuatu High Risk Prohibited
Venezuela Prohibited Prohibited
Vietnam High Risk Prohibited
Yemen Prohibited Prohibited
Zambia High Risk High Risk
Zimbabwe High Risk Prohibited