African Export-Import Bank Banque Africaine d’Import-Export

African Export-Import Bank

Banque Africaine d’Import-Export

Afreximbank Building, 72 (B) El Maahad El Eshteraky Street – Heliopolis, Cairo 11341, Egypt

P.O. Box 613 Heliopolis, Cairo 11757, Egypt

Tel: [phone];

Fax : [phone]

Website : www.afreximbank.com

Anti-Money Laundering/ Know Your Customer Compliance Questionnaire for Correspondent Banking Relationships

		COMPANY PROFILE
1		NAME OF INSTITUTION (please attach certificate of incorporation)
2		SWIFT BIC
3		Website Address
4		Full address of the institution
5		Place of registration (please attach registration certificate)
6		Legal Status (please attached memorandum and articles of association)		Limited Company  Government Bank  Cooperative Bank  Savings Bank (under Special Law)  Others (please specify)
7		External Auditor (name, address, contact details i.e. tel/fax/email/website)
8		Legal Advisors (name, address, contact details i.e. tel/fax/email/website)
9		Shareholder’s equity		(as of latest reporting period)
10		Listing Are your shares listed in any Stock Exchange Market(s)?		 Yes Name of Stock Exchange Market(s): Your stock symbol:
 No
11				Primary regulatory body(ies) Please list names of the primary regulatory body (ies) that supervise(s) your institution and attach the relevant registration certificates.
12		Banking License (please attach banking license)		 Yes  No a) issued by: b) Banking license type: c) Year of issuance: d) Is your bank authorized to hold foreign currency accounts outside of your country?  Yes  No e) Are there any restriction on this authorization? Yes  No f) Is your bank authorized to trade foreign exchange? Yes  No g) Bank's tax identification number (if any): h) Number of Domestic branches: i) Number of Foreign branches:  N/A (We are not Bank)
13		Number of employees
14		Ratings:
15		Main Business (e.g. Retail banking, Corporate banking, Investment banking etc.)
16		Board of Directors and Executive Management 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		Name Nationality Title Board Membership Tenure: Years
17		Affiliates/Subsidiaries/Parent/Holding Companies
18		Financial products & services What type of financial products and services do your bank offer to your customers?
19		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 Precious Stones, Money Service Business, Lawyers, Notaries, Other Independent Legal Professionals and Accountants, Trust and Service Providers		 Yes (*) (*) 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.
20				Specific Laws and / or Regulations covering AML Are there any specific laws and/or regulations in place covering Anti-Money Laundering?		 Yes Please list them  No
21	Enforcement action Has your bank been fined or received any enforcement action by your regulator for a breach of Anti-Money Laundering legislation?		 Yes Please attach details
			 No
22	Payable-through accounts^1 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?		 Yes 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?  Yes  No
			 No
		OWNERSHIP STRUCTURE/ULTIMATE BENEFICIAL OWNER
Name of Person/Company		% Shareholding		Business Address(House#/Street/Town/City/Country)
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		% Shareholding		Business Address(House#/Street/Town/City/Country)
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		Comments
Is your institution subject to laws and regulations designed to combat money laundering and Terrorist financing (AML/CFT)? Name the law(s)		 Yes  No
Is Money Laundering/Terrorist Financing Criminalized in your country?		 Yes  No
Does your country comply with the recommendations of FATF or any equivalent regional styled body? Please specify.		 Yes  No
Does your institution have AML compliance programme approved by your board or a senior management committee?		 Yes  No
Do you have a designated officer that is responsible for coordinating and overseeing your AML/CFT programme?		 Yes  No
Has your institution developed written policies documenting the processes that you have in place to prevent, detect and report suspicious transactions?		 Yes  No
Do you have an internal audit function that assesses your AML/CFT policies and practices on a regular basis?		 Yes  No
Does your institution have a policy prohibiting accounts/relationships with shell banks or customers linked with shell banks?^2		 Yes  No
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?		 Yes  No
Do you have policies covering the establishment and maintenance of relationships with Politically Exposed Persons (PEP’s), their family and close associates?		 Yes  No
Does your institution have record retention procedures that comply with applicable law? If yes, how many years do you keep records?		 Yes  No
Are your AML/CFT policies and practices being applied to all branches and subsidiaries?		 Yes  No
Do your policies and procedures permit you to open or maintain anonymous accounts or numbered accounts?		 Yes  No
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?		 Yes  No
Does your institution confirm the existence of clients via independent source documents?		 Yes  No
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?		 Yes  No
2. Risk Assessment		Yes / No		Comments
Does your institution have a risk-based assessment of its customer base and their transactions?		 Yes  No
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?		 Yes  No
Does your institution perform Risk Assessments of its product, services, branches and customers? If “yes” at what interval do you undertake this project/task?		 Yes  No
3. Know Your Customer, Due Diligence and Enhanced Due Diligence		Yes / No		Comments
Has your institution implemented processes for the identification your customers?		 Yes  No
Do you have a requirement to collect information regarding your customers’ business activities?		 Yes  No
Does your institution have a process to review and, where appropriate, update customer information relating to high risk client information?		 Yes  No
Do your CDD/KYC procedures require you to identify the source of your Customers’ initial funds?		 Yes  No
Does your institution have procedures to establish a record for each new customer noting their respective identification documents and ‘Know Your Customer’ information?		 Yes  No
Does your institution complete a risk-based assessment to understand the normal and expected transactions of its customers?		 Yes  No
Do your Customer identification and verification, and on-going due diligence procedures meet the current Recommendations of the FATF?		 Yes  No
When you are conducting wire transfers for your customers, do you require sender and beneficiary names, account numbers and reason for the transfer?		 Yes  No
4. Reportable Transactions and Prevention and Detection of Transactions with Illegally Obtained Funds		Yes / No		Comments
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?		 Yes  No
Does your institution have procedures to identify transactions structured to avoid cash transaction reporting threshold?		 Yes  No
Do you screen your customers and their transactions against any sanction list?		 Yes  No
Has your institution filed a suspicious transactions report with the financial intelligence center in the past two (2) years?		 Yes  No
5. Transaction Monitoring		Yes / No		Comments
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?		 Yes  No
Does your institution have a system (AML Software) for detecting abnormal customer transactions or patterns of activity in relation to the expected norm?		 Yes  No
6. AML Training		Yes / No		Comments
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. ?		 Yes  No
Do you retain records of training sessions including attendance records and relevant training materials used?		 Yes  No
Does your institution communicate new AML/CFT related laws or changes to existing AML/CFT related policies or practices to relevant employees?		 Yes  No
NAME OF COMPLIANCE OFFICER
DESIGNATION
FULL ADDRESS
EMAIL ADDRESS
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.

COMPLETED BY
POSITION
EMAIL:
SIGNATURE & STAMP

Kindly attach the following additional documents when submitting this questionnaire:

1. 
   Current List of Board of Directors & Senior Management, brief profiles and copies of identification.
   
2. 
   Current KYC / AML Policy
   
3. 
   Latest annual report
   

1^ Payable-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)

2^ 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 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.