Financial Crime
Programme
MYRA Bank Ltd operates a risk-based financial crime programme covering: customer due diligence and enhanced due diligence; verification of identity and of beneficial ownership; source-of-wealth and source-of-funds verification for every relationship; ongoing monitoring and periodic review; transaction monitoring against recognised typologies; sanctions and politically-exposed-person screening at onboarding and continuously thereafter; record retention for the statutory period; staff training; independent testing; and reporting of suspicious activity to the competent authority.
What MYRA does not do
MYRA does not open anonymous or numbered accounts.
MYRA does not accept nominee or intermediary arrangements that obscure beneficial ownership.
MYRA does not establish or maintain relationships with shell banks.
MYRA does not permit nested, downstream or payable-through use of its accounts by other financial institutions.
MYRA does not accept clients who decline to evidence source of wealth, and does not offer expedited onboarding in exchange for reduced documentation.
MYRA does not establish or administer structures whose purpose is to obscure beneficial ownership, to avoid automatic exchange of information, or to shield assets from lawful creditors.
Sanctions
MYRA screens all clients, beneficial owners, counterparties and transactions against the consolidated lists of the United Nations Security Council, the European Union, the United States Office of Foreign Assets Control, the United Kingdom Office of Financial Sanctions Implementation, and the Union of the Comoros.
MYRA does not establish or maintain relationships involving Iran, North Korea, Syria, Cuba, or the Crimea, Donetsk, Luhansk, Kherson and Zaporizhzhia regions; nor with designated persons or entities; nor with entities owned or controlled 50 per cent or more, directly or indirectly, by designated persons.
Payments may be delayed, returned, rejected or blocked where MYRA or a correspondent institution is required to do so. MYRA is not liable for losses arising from action taken to comply with sanctions obligations.
Prohibited activities
MYRA does not bank: unlicensed gambling or gaming; unlicensed money services businesses, payment aggregators or remittance operators; unlicensed virtual asset service providers; adult entertainment; arms, munitions and dual-use goods; unlicensed pharmaceuticals; and shell companies without demonstrable economic purpose.
Relationships in these sectors are declined at onboarding and terminated where identified subsequently.
Confidentiality and its limits
Client confidentiality is a professional obligation, not a shield. It does not extend to lawful requests from competent authorities, to sanctions obligations, to suspicious activity reporting, or to the information MYRA is required to share with correspondent institutions in the course of settling a payment.