The PNC Financial Services Group, Inc., its branches and majority owned subsidiaries (collectively "PNC") have adopted and implemented an Anti-Money Laundering and Sanctions Program ("AML Program"). The AML Program complies with all applicable laws and regulations regarding sanctions, money laundering, terrorist financing, and other financial crimes.
The PNC Financial Services Group, Inc. is regulated by the U.S. Federal Reserve Bank of Cleveland; its subsidiaries in the United States are regulated by several regulatory agencies including, but not limited to the Office of the Comptroller of the Currency, the Securities and Exchange Commission, the Commodity Futures Trading Commission, Federal Deposit Insurance Corporation, Consumer Financial Protection Bureau, and the Financial Industry Regulatory Authority. Outside the United States, PNC subsidiaries are subject to local regulatory oversight.
PNC has implemented a risk-based, enterprise-wide AML Program that complies with both the specific provisions and the spirit of all relevant laws and regulations. Accordingly, PNC’s AML Program includes, but is not limited to:
- Appointment of an AML Officer
- A Customer Identification Program designed to identify and verify all customers, and where applicable, beneficial owners, to the extent warranted by the risk of money laundering or terrorist financing, or as required by regulation
- Performing Customer Due Diligence and Enhanced Due Diligence on higher risk customers
- Regular independent testing
- An AML training program for appropriate personnel
- Processes and systems to monitor customer transactions and to identify potentially suspicious activity
- Reporting of suspicious activity to appropriate regulatory bodies
- Forbidding direct or indirect services to shell banks
- Policies and controls to ensure compliance with sanctions programs
The Risk Committee of the Board of Directors has appointed an enterprise-wide Chief AML Compliance Executive who serves as PNC’s primary point of contact with PNC’s regulatory authorities on AML and sanctions matters, and oversees PNC’s compliance with AML and sanctions requirement.