Given that a large part of the activity for the purpose of money laundering is carried out through the banking system, in order to prevent financial institutions from serving as tools in the hands of money launderers, and in order to harness the efficiency, computerization, and globalization of the global financial systems to the war against money laundering and terrorism, various countries, including Israel, have imposed a series of obligations on the banking system [ibid.). Thus, within the framework of the provisions relating to the prohibitions regarding money laundering in accordance with theProhibition of Money Laundering Law, 5760-2000 (hereinafter: the "Prohibition of Money Laundering Law") and the Prohibition of Money Laundering Order (Obligations to Identify, Report and Maintain Records of Banking Corporations for the Prevention of Money Laundering and Terrorist Financing), 5761-2001 (hereinafter: the "Order") - the banking corporation was imposed, in parallel with its business activity, administrative roles, including, Obligations to receive information that will be used to locate activities related to money laundering or terrorist financing and to take action - including reporting in order to prevent prohibited activity [see the judgment in the case of the Emar Association; the judgment in the Renaissance case; Civil Appeal 3497/15 Yassin Empire for Investments and Finance in Tax Appeal v. Bank Hapoalim in Tax Appeal [published in Nevo] (November 11, 2015) (hereinafter: "The Judgment in the Yassin Empire Case")].
It should be emphasized that where the bank fails to fulfill the obligations imposed on it by virtue of the law, criminal liability may be established against the bank or its employees [section 7(c) of the Law and section 12 of the Order] and the bank may also be subject to a civil sanction - a financial sanction in accordance with Section 14 of the Prohibition of Money Laundering Law. It should be emphasized that financial sanctions in Israel are not the be-all and end-all, as banking corporations operating abroad are also expected to be subject to financial sanctions there as well (in this context, I will note in a closed article a payment of about ILS 1 billion that Bank Leumi bore in the United States and the provision of similar sums by Bank Hapoalim due to investigations in this context).