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This questionnaire acts as an aid to firms conducting due diligence and should not be relied on exclusively   or excessively. Firms may use this questionnaire alongside their own policies and procedures in order to provide a basis for conducting client due diligence in a manner  consistent  with the risk profile presented   by the client. The responsibility for ensuring adequate due diligence, which may include independent verification or follow up of the answers and documents provided, remains  the responsibility  of the firm  using  this questionnaire.

 

Anti - Money Laundering Questionnaire
If you answer "no" to any question, additional information can be supplied at the end of the questionnaire.
I. General AML Policies, Practices and Procedures Y N

Is the AML compliance program approved by the FI's board or a senior committee?

Y  

Does the FI have a legal and regulatory compliance program that includes a designated officer that is responsible for coordinating and overseeing the AML framework?

Y  

Has the FI developed written policies documenting  the processes that they have in place to prevent, detect and report suspicious transactions?

Y  

In addition to inspections by the government supervisors/regulators, does the FI client have an internal audit function or other independent third party that assesses AML policies and practices on a regular basis?

Y  

Does the FI have a policy prohibiting accounts/relationships with shell banks? (A shell bank is defined as a bank incorporated in a jurisdiction in which it has no physical presence  and  which is unaffiliated  with a regulated financial

Y  

Does the FI have policies to reasonably ensure that they  will not conduct transactions with or on  behalf of shell  banks through an   of its accounts or products?

Y  

Does the FI have policies covering relationships with Politically Exposed Persons PEP's their family and close associates?

Y  

Does the FI have record retention procedures that comply with applicable law?

Y  

Are the FI's AML policies and practices being applied to all branches and subsidiaries of the FI both in the home country and in locations outside of that jurisdiction?

Y  
II. Risk Assessment

Does the FI have a risk-based assessment of its customer base and their transactions?

Y  

Does the FI determine the appropriate level of enhanced due diligence necessary for those categories of customers and transactions that the FI has reason to believe pose a heightened risk of illicit activities at or through the FI?

Y  
III. Know Your Customer, Due Diligence and Enhanced Due Diligence:

Has the FI implemented processes for the identification of those customers on whose behalf it maintains or operates accounts or conducts transactions?

Y  
Does the FI have a requirement to collect information regarding its customers' business activities? Y  
Does the FI assess its FI customers' AML policies or practices. Y  
Does the FI have a process to review and, where appropriate, update customer information relating to high risk client information? Y  
Does the FI have procedures to establish a record for each new customer noting their respective identification documents and 'Know Your Customer' information? Y  
IV. Reportable Transactions and Prevention and Detection of Transaction with Illegally Obtained Funds:

Does the FI complete a risk-based assessment to understand the normal and ex ected transactions of its customers?

Y  
Does the FI have policies or practices for the identification and reporting of transactions that are required to be reported to the authorities? Y  
Where cash transaction reporting is mandatory, does the FI have procedures to identify transactions structured to avoid such obligations? Y  
Does the FI screen customers and transactions against lists of persons, entities or countries issued by government/competent authorities? Y  
Does the FI have policies to reasonably ensure that it only operates with correspondent banks that possess licenses to operate in their countries of origin? Y  
Does the FI adhere to the Wolfsberg Transparency Principles and the appropriate usage of the SWIFT MT 202/202COV and MT 205/205COV message formats?*   N
V. Transaction Monitoring
Does the FI have a monitoring program for unusual and potentially suspicious activity that covers funds transfers and monetary instruments such as travelers checks, money orders, etc? N/A N/A

 * The four payment message standards to be observed a re: i) Fis should not omit, delete, or alter information in payment messages or orders for the purpose of avoiding detection of that info rmation by any ot her FI in the payment process; ii) Fls should not use any particula r payment message for the purpose of avoiding detection of information by any other FIin the pay ment process; iii) Subjec t to applicable laws, Fls should cooperate as fully as practicable with other Fis in the payment process when requesting to provide information about the parties involved; and (iv) Fis should strongly encourage their correspondent ba nks to observe these principles. Source: http://www.wolfsbe rq- principles.com/pdf/ standards/ Wolfsberq  NYCH Statement on Payment Message Standards  [2007).pdf

 The Wolfsberg Group consists of the following leading international financial institutions : Banco Santander, Bank of Tokyo-Mitsubishi UFJ, Barclays, Citigroup, Credit Suisse, Deutsche Bank, Goldman Sachs, HSBC, JP Morgan Chase, Societe Generale and UBS which aim to develop financial services industry standards, and related products, for Know Your Customer, Ant i-Money Laundering and Counter Terrorist Financing policies.


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