Please provide a Register of Directors or signed declaration on the Company’s letterhead confirming the current Board of Directors and Executive Management team and their profiles
Board Membership Tenure: Years
Financial products & services
What type of financial products and services do your bank offer to your customers?
Customers' Major Business segments
Please describe your customers’ major business segments. Do they include the following business?
(*) Casinos, Real Estate Agents,
Dealers in Precious Metals and
Money Service Business,
Other Independent Legal Professionals
Trust and Service Providers
(*) These segments afore mentioned occupy more than 25% shares in terms of customer portfolio of your institution.
No Please list your customers’ major business segments.
Specific Laws and / or Regulations
Are there any specific laws and/or regulations in place covering Anti-Money Laundering?
Please list them
Has your bank been fined or received any enforcement action by your regulator for a breach of Anti-Money Laundering legislation?
Please attach details
Does your bank allow direct use of your correspondent accounts by your customers to transact business on their behalf? I.e. Do you allow Payable-through accounts?
a) Have you verified the identity of and performed on-going due diligence on your customers having direct access to your correspondent accounts?
Yes No b) Are you able to provide relevant customer identification data upon request?
If any of the owners above is a Legal Entity, please list the names of the shareholders of that Legal Entity, Shareholders, percentage of ownership (shareholding), and contact details
Name of Person/Company
The questionnaire below requires “Yes”/ “No” answers. Kindly note that an answer “yes” or “no” may also require additional information which can be supplied in the column for comments.
1. General AML Policies, Practices and Procedures:
Yes / No
Is your institution subject to laws and regulations designed to combat money laundering and Terrorist financing (AML/CFT)? Name the law(s)
Is Money Laundering/Terrorist Financing Criminalized in your country?
Does your country comply with the recommendations of FATF or any equivalent regional styled body? Please specify.
Does your institution have AML compliance programme approved by your board or a senior management committee?
Do you have a designated officer that is responsible for coordinating and overseeing your AML/CFT programme?
Has your institution developed written policies documenting the processes that you have in place to prevent, detect and report suspicious transactions?
Do you have an internal audit function that assesses your AML/CFT policies and practices on a regular basis?
Does your institution have a policy prohibiting accounts/relationships with shell banks or customers linked with shell banks?2
Do you have policies to reasonably ensure that you will not conduct transactions with or on behalf of shell banks through any of your accounts or products?
Do you have policies covering the establishment and maintenance of relationships with Politically Exposed Persons (PEP’s), their family and close associates?
Does your institution have record retention procedures that comply with applicable law? If yes, how many years do you keep records?
Are your AML/CFT policies and practices being applied to all branches and subsidiaries?
Do your policies and procedures permit you to open or maintain anonymous accounts or numbered accounts?
Does your institution initiate/process transactions on behalf of non-clients (i.e. clients who conduct once –off transactions); if yes do you conduct identification and verification on these types of clients?
Does your institution confirm the existence of clients via independent source documents?
Has your institution been subject to any investigation, indictment, conviction, or civil enforcement related to money laundering and terrorist financing in the past five years?
2. Risk Assessment
Yes / No
Does your institution have a risk-based assessment of its customer base and their transactions?
Does your institution determine the appropriate level of enhanced due diligence necessary for those categories of customers and transactions that you have reason to believe pose a heightened risk of illicit activities?
Does your institution perform Risk Assessments of its product, services, branches and customers? If “yes” at what interval do you undertake this project/task?
Has your institution implemented processes for the identification your customers?
Do you have a requirement to collect information regarding your customers’ business activities?
Does your institution have a process to review and, where appropriate, update customer information relating to high risk client information?
Do your CDD/KYC procedures require you to identify the source of your Customers’ initial funds?
Does your institution have procedures to establish a record for each new customer noting their respective identification documents and ‘Know Your Customer’ information?
Does your institution complete a risk-based assessment to understand the normal and expected transactions of its customers?
Do your Customer identification and verification, and on-going due diligence procedures meet the current Recommendations of the FATF?
When you are conducting wire transfers for your customers, do you require sender and beneficiary names, account numbers and reason for the transfer?
4. Reportable Transactions and Prevention and Detection of Transactions with Illegally Obtained Funds
Yes / No
Does your institution have policies or practices for the identification and reporting of transactions that are required to be reported to the Financial Intelligence Center?
Does your institution have procedures to identify transactions structured to avoid cash transaction reporting threshold?
Do you screen your customers and their transactions against any sanction list?
Has your institution filed a suspicious transactions report with the financial intelligence center in the past two (2) years?
5. Transaction Monitoring
Yes / No
Does your institution have a monitoring program to identify unusual and potentially suspicious transactions that cover funds transfers and monetary instruments such as managers’ cheques, payment orders, etc?
Does your institution have a system (AML Software) for detecting abnormal customer transactions or patterns of activity in relation to the expected norm?
6. AML Training
Yes / No
Does your institution provide AML/CFT training to relevant employees that includes:
Identification and reporting of transactions that must be reported to FIC.
Examples of different forms of money laundering involving your products and services. ?
Do you retain records of training sessions including attendance records and relevant training materials used?
Does your institution communicate new AML/CFT related laws or changes to existing AML/CFT related policies or practices to relevant employees?
NAME OF COMPLIANCE OFFICER
PHONE & FAX NUMBERS
SIGNATURE & STAMP & DATE
The undersigned, based on his/her best knowledge, certifies that the above referenced questions were answered, and further presents, an accurate representation of the state of the institution’s anti-money laundering and anti-terrorist financing, in accordance with its internal controls and operational activities.
SIGNATURE & STAMP
Kindly attach the following additional documents when submitting this questionnaire:
Current List of Board of Directors & Senior Management, brief profiles and copies of identification.
Current KYC / AML Policy
Latest annual report
1Payable-through accounts：The above questions are based on Recommendation 7-(e) of FATF's "The Forty Recommendations". The background of the question is that "pass through account" is considered by the regulators as high risk for potential money laundering thus we need to verify that you have some kind of mechanism in place to reduce the risk of money laundering by asking you the additional questions a) & b)
2A 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 group.
Afrex/CU/KYCInst/AML/Qstn/2015 Please Note that the questionnaire must be completed and signed by an authorized individual (e.g., Legal, compliance or business representative) from the Financial Institution.