In executing measures to counteract the legalization (laundering) of proceeds of crime, the financing of terrorism, and the financing of the proliferation of weapons of mass destruction, Business Development Bank (hereinafter – the Bank) operates in full compliance with the applicable legislation of the Republic of Uzbekistan. The Bank ensures strict adherence to the regulatory requirements of the Central Bank of the Republic of Uzbekistan and aligns its policies with the recommendations of the Financial Action Task Force (FATF) to uphold anti-money laundering (AML) and counter-terrorism financing (CTF) obligations in accordance with international standards.

• Transaction Participants – Clients, their authorized representatives, and the client’s partners directly involved in the transaction.

• Beneficial Owner – An individual who ultimately owns, exercises control over, or derives benefit from the client’s assets and in whose interest a financial transaction or operation involving monetary funds or other property is conducted.

• Politically Exposed Persons (PEPs) – Individuals who are appointed or elected, whether permanently, temporarily, or under special authority, to perform organizational, managerial, or legally significant functions within legislative, executive, administrative, or judicial bodies, including military structures of a foreign state or an international organization. This category also includes senior executives of foreign enterprises, prominent political figures, and recognized members of political parties in foreign states, including former officials.

In compliance with the requirements of Law No. 2886 and to uphold both its own and its clients' business reputation at the highest level, Business Development Bank adheres to the "Know Your Customer" (KYC) principle, which includes the following key measures:

• Customer Due Diligence (CDD) – Verification of the client's identity and legal authority, identification of the beneficial owner, and ongoing monitoring of business relationships and transactions to ensure their consistency with the client’s declared activities and risk profile.

• Client Identification – Collection and verification of client information by the bank based on official documents submitted by the client, as well as supplementary data from publicly available sources and regulatory databases, to conduct proper due diligence.

• Beneficial Ownership Identification – Determination of the individual or legal entity that ultimately owns or controls the client. This process includes a comprehensive review of the client’s ownership and governance structure, as outlined in its charter, incorporation agreement, or other statutory documents, in accordance with applicable legal requirements.

To verify client information, including representatives and beneficiaries, clients must submit a complete set of required documents to the bank.

Identification Requirements for Individuals

• Client identification for individuals is conducted by the bank based on an official identification document, such as a passport, national ID card, or an equivalent document, or through biometric data verification.

• When verifying a client’s identity, the bank must:

  • Examine the original identification document (passport, national ID card, or its equivalent).

  • If using biometric data, verify the information through the information system of the Ministry of Internal Affairs of the Republic of Uzbekistan.

Identification Requirements for Legal Entities

Clients that are legal entities must provide the following information:

a) Full and, if applicable, abbreviated company name as stated in the certificate of state registration.
b) State registration details: date, registration number, and name of the registering authority.
c) Taxpayer identification number (TIN).
d) Registered address (postal address) and, if different, the address of the head office.
e) Other relevant information contained in the certificate of state registration.
f) Licensing details, if applicable: type of licensed activity, license number, issuance date, issuing authority, and validity period.
g) Identification details of individuals authorized to sign documents or act on behalf of the legal entity.
h) Information on founders, major shareholders, or participants, including their ownership stakes in the company’s charter capital.
i) Amount of registered and paid-in charter capital.
j) Governance structure, including the composition and structure of management bodies.
k) Contact phone numbers.

Identification Requirements for Sole Proprietors

Sole proprietors must provide:

a) Information as required under Appendix 1 of the Internal Control Rules for Combating the Legalization of Proceeds from Criminal Activities and the Financing of Terrorism in Commercial Banks.
b) State registration details: date, registration number, and name of the registering authority.
c) Place of business operations.
d) Additional details as outlined in the certificate of state registration.
e) Information on permits and licenses, including type of activity, license number, issuance date, issuing authority, and validity period.
f) Contact phone numbers.

Client information obtained through due diligence must be updated based on its significance and associated risks. Updates must also be made whenever there are changes to the client’s information.

• If the commercial bank assesses the client’s risk level for money laundering, terrorist financing, or the financing of weapons of mass destruction as high, the identification data must be updated at least once a year.

• In all other cases, client identification information must be updated at least once every two years.

To maintain the business reputation of both the Bank and its clients, and in line with the implementation of the Know Your Customer (KYC) principle, the Bank may request the following:

• Documents substantiating transactions conducted through the client’s bank account.

• Written explanations regarding the economic rationale of transactions.

• Information and/or documents on the source of funds or other assets and the intended purpose of their use.

• Information and/or documents regarding the purpose of the client’s business activities and financial position.

• Details on the client’s key counterparties.

• Information on relationships between transaction participants within affiliated companies and their roles within the corporate group.

• Information and/or documents on beneficiaries when transactions are carried out on behalf of third parties.

• Any other documents or explanations as required, based on the nature of the client’s transactions and business activities.

The Bank independently determines the scope, deadlines, and review process for the requested documents and/or information, taking into account the nature of the client’s transactions and business activities.

A commercial bank is required to classify clients as high risk if they meet any of the following criteria, requiring enhanced due diligence and increased monitoring:

a) Individuals or entities listed on the Sanctions List, as well as organizations owned or controlled by such individuals, or entities directly or indirectly owned or controlled by a sanctioned person.
b) Individuals residing, located, or registered in a jurisdiction that does not participate in international cooperation on anti-money laundering (AML) and counter-terrorism financing (CTF) efforts.
c) Foreign company representatives and non-resident individuals of the Republic of Uzbekistan.
d) Individuals residing, located, or registered in offshore jurisdictions.
e) Residents and non-residents holding bank accounts in offshore jurisdictions.
f) Organizations and sole proprietors whose actual location does not match the address specified in their incorporation or registration documents.
g) Organizations whose beneficial owner falls under categories (a) or (b) of this section.
h) Clients engaging in suspicious or questionable transactions on a recurring basis (e.g., for three consecutive months).
i) Clients using software or technological solutions that prevent proper due diligence and client verification.
j) Politically exposed persons (PEPs), their family members, and close associates.
k) Other individuals or entities as determined by the bank’s internal policies.

Pursuant to Law No. 2886, commercial banks are legally authorized to refuse to execute transactions for a client in the following circumstances:

• Failure to maintain a presence at the registered business address, including the absence of the governing body of a legal entity or an authorized representative empowered to act on behalf of the legal entity without a power of attorney.

• Submission of fraudulent, false, or misleading documents, or failure to provide required documentation as mandated by applicable legislation.

• Any other instances as prescribed by law.

Pursuant to applicable legislation, commercial banks are strictly prohibited from:

• Opening accounts (deposits) for anonymous owners, meaning individuals or legal entities that fail to provide the required identification documents when opening an account.

• Opening accounts under fictitious names that are not supported by valid documentation.

• Opening accounts without the personal presence of the account holder or their authorized representative, except in cases where:

  • The commercial bank can verify the client’s identity based on previously submitted, valid, and verified documents as of the identification date.

  • The client’s due diligence has been conducted by the registering authority or the commercial bank using biometric data.

  • The commercial bank relies on customer due diligence (CDD) conducted by a third party in accordance with applicable regulations.

• Establishing or maintaining correspondent relationships with non-resident banks that lack a physical presence or permanent management structure in the jurisdiction where they are registered.

• Issuing bearer securities or other financial instruments that do not require registered ownership.

• Providing foreign currency remittance services, including international money transfer systems, without conducting client identification.

• Establishing subsidiary banks, branches, or representative offices in jurisdictions that do not participate in international cooperation on anti-money laundering (AML) and counter-terrorism financing (CTF).

In cases where a commercial bank is unable to properly verify a client’s identity, it must consider reporting the matter to the designated regulatory authority. Additionally, the bank must either refrain from establishing a business relationship with the client, suspend transactions, or terminate any existing business relationship if proper due diligence cannot be conducted.

General Guidelines

• Engage proactively with the bank regarding any inquiries or compliance-related matters.

• Transparency and cooperation with the bank are essential for maintaining a secure and productive financial relationship.

• Provide all requested information and documentation to the bank in a timely manner, as required by applicable regulations.

• Notify the bank of any changes to your identification details and submit supporting documentation within the timeframe stipulated in your agreement with the bank.

• Safeguard your business reputation by refraining from participating in financial schemes of a questionable nature, particularly those associated with money laundering (AML), terrorist financing (CTF), or the financing of weapons of mass destruction (WMD).

• Be advised that liability measures are enforced under Articles 155-3 and 243 of the Criminal Code of the Republic of Uzbekistan.

Guidelines for Legal Entities

• Conduct transactions strictly in accordance with your company’s charter, registration documents, and declared business activities as provided at the time of account opening.

• Notify the bank promptly of any changes in your company’s business activities.

• Ensure that all financial transactions conducted through your corporate account align with the primary business activities of your entity.

Guidelines for Individuals

• Do not use your personal current account or bank card for commercial or business purposes. If engaging in entrepreneurial activities, register as a sole proprietor and open a dedicated business account.

• Do not transfer, sell, or allow third-party use of your bank card in exchange for compensation. Unauthorized use of your card may facilitate illicit financial activities, including money laundering and fraudulent schemes.

• Do not engage in third-party financial transactions for compensation, including receiving wire transfers into your account and subsequently withdrawing funds in cash or transferring them to other individuals. Such activities may constitute financial crimes under applicable legislation.