The following guidelines are understood to be appropriate for private banking relationships. Guidelines for other market segments may differ. It is recognized that the establishment of policies and procedures to adhere to these guidelines is the responsibility of management.

Client acceptance: general guidelines

General

Bank policy will be to prevent the use of its worldwide operations for criminal purposes. The bank will endeavor to accept only those clients whose source of wealth and funds can be reasonably established to be legitimate. The primary responsibility for this lies with the private banker who sponsors the client for acceptance. Mere fulfillment of internal review procedures does not relieve the private banker of this basic responsibility.

Identification

The bank will take reasonable measures to establish the identity of its clients and beneficial owners and will only accept clients when this process has been completed.

Client

• Natural persons: identity will be established to the bank's satisfaction by reference to official identity papers or such other evidence as may be appropriate under the circumstances.
• Corporations, partnerships, foundations: the bank will receive documentary evidence of the due organization and existence.
• Trusts: the bank will receive appropriate evidence of formation and existence along with identity of the trustees.
• Identification documents must be current at the time of opening.

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