Ousmane Coulibaly

*Update of the AML-CFT risk mapping aligned with french regulations *Update of the AML-CFT policy (MICA Regulation, alignment with the “PSCA” qualification, etc.) *London’s operational team support regarding regulatory french requirements *AML-CFT regulatory monitoring (update of the FATF list, alignment with MICA regulations, monitoring of changes in the lists of sanctioned countries or individuals) *Contribution to the Supervisory Board report on new account openings for the European subsidiary *Implementation of the CRS (Customer Reporting Standards) form for BCB Payments Europe corporate clients *Initiation of annual AML-CFT training for staff and new employees *Approvals of new/migrated customers onboarded to BCB Payments Europe *AML/CFT risk-based approach dedicated to non-compliant customers *Framework implementation in accordance with internal AML-CFT /operational risks policies (initiation of PVID certified by ANSSI for the European subsidiary, reporting of onboarded/rejected customers, monitoring of the ratio of “high risk” customers)

*Draft and validation of Compliance Waiver and Exemption Requests *Enhanced due diligence on high risk country customers & PEP individuals *Update of the Customer Periodical Reviews for the private banking department *Override escalation with London Compliance MLRO for Customers’ Risk assessment *Compliance’s approval following customers’ scoring risk mitigation *Suggestion of improved ‘’Customer’s identification’’ procedure through sample of private banking customers *Coordination with Relationship Managers on-boarding clients as per Bank’s policies & procedures *Assessment of Customers financial profile and transactions (Source of Wealth / Source of Funds) *Update of Ultimate Beneficiary Owners and Relatives Closed associates *Screenings of individual and Corportate clients with Google, Datanomics & Safewatch *Screenings of a customer sample following the "Pandora Papers" publication list *Gap Analysis on the KYC Status of Compliant / Non-Compliant Files *Due diligence on inter-banking transactions and correspondences with external compliance services *Traineeship & enrolment of Relationship Officer for clients Due Diligence and SOF/SOW analysis

*AML/CFT Analysis among BPCE clients’ complementary informations files *Identification and updates of Ultimate Beneficial Owners regarding 5th european directive *Management of sanctions lists updates confronted to clients basis *Management of potential PEP’s alerts and sanctions lists on Firecoweb (Dowjones Factiva, OFAC) *Enhanced Due Diligence of high risk operations *Settlement of AML committees related to atypical clients

*Draft « Current accounts » process regarding dormant accounts (Eckert law) *Co-animation of validation committees of “Current accounts ” and “Credit Cards ” *Draft reports of validation committees *Update of KYC categories check-list for new clients relationship *2nd level control (attendance of control files, setting up corrections)

*Annual reports and due diligence on special category clients *Assessment of financial transactions and source of wealth *Risks acceptance and exit decisions regarding sensitive clients *Identification of Ultimate Beneficial Owners, sanctions lists and negative news Screening e-tools : -Dowjones Factiva Risk Compliance -Netreveal AML -RDC Smarter Screening

*Implementation of AML/CFT through IGOR Filtering & SIRON AML Profiling e-tools *Involvement in updating compliance procedures *Draft and consolidation of weekly reports *Draft compliance instances related to letters of credit and new partnership *Audit on opening accounts based on KYC check-list in Paris and Marseille branches *Control of financial sanctions lists and PEP (UN,CE,FR,OFAC,PPE DOWJONES) *Enhanced Due Diligence and suspicious Activity Reports on atypical accounts Screening e-tools : -Dowjones Factiva Risk Compliance -IGOR LN Filtrage -SIRON AML Profilage