1.Your institution’s information

Financial Institution Name:

Location:

Website Address:

Please describe your primary line of business:

If applicable, name of stock exchange listed on:

Stock symbol:

Name of persons or any legal or organisational entity who owns or controls more than 10% of the shares in your good institution, with percentages indicated for each shareholder:

Current list of your good Institution’s Board of Directors and senior management:

Name of the banking supervisory authority in your country:

Name of your anti-money laundering and/or anti-terrorist financing (“AML”) regulatory authority:

General AML Policies, Practices and Procedures

1

Does the AML Compliance program require approval of the FI’s Board or a senior committee thereof?

 Yes  No

2

Does the FI have a legal and regulatory compliance program that includes a designated Compliance officer that is responsible for coordinating and overseeing the AML program on a day-to-day basis that has been approved by senior management of the FI?

 Yes  No

3

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

 Yes  No

4

Do your AML policies and procedures meet the current recommendations developed by the Financial Action Task Force (“FATF”)?

 Yes  No

5

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

 Yes  No

6

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 group)?

 Yes  No

7

Does the FI have appropriate record retention procedures pursuant to applicable law?

 Yes  No

8

Does the FI require that its AML policies and practices be applied to all branches and subsidiaries of the FI both in the home country and in locations outside of the home country?

 Yes  No

9

Is the FI in compliance with anti-money laundering/anti-terrorist financing legislation in its own jurisdiction?

 Yes  No

Risk Assessment

10

Does the FI have a risk-focused assessment of its customer base and transactions of its customers?

 Yes  No

11

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?

 Yes  No

Know Your Customer, Due Diligence and Enhanced Due Diligence

12

Has the FI implemented systems for the identification of its customers, including customer information in the case of recorded transactions, account opening, etc. (for example: name, nationality, street address, telephone number, occupation, age/date of birth, number and type of valid official identification, as well as the name of the country/state or province that issued it)?

 Yes  No

13

Does the FI have a requirement to collect information regarding its customers’ business activities?

 Yes  No

14

Does the FI collect information and assess its FI customers’ AML policies or practices?

 Yes  No

15

Does the FI take steps to understand the normal and expected transactions of its customers based on its risk assessment of its customers?

 Yes  No

Reportable Transactions and Prevention and Detection of Transactions with Illegally Obtained Funds

16

Does the FI have policies or practices for the identification and reporting of transactions that are required to be reported to the authorities?

 Yes  No

17

Does the FI have procedures to identify transactions structured to avoid large cash reporting requirements?

 Yes  No

18

Does the FI screen transactions for customers or transactions the FI deems to be of significantly high risk (which may include persons, entities or countries that are contained on lists issued by governments/international bodies) that special attention to such customers or transactions is necessary prior to completing any such transactions?

 Yes  No

19

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

 Yes  No

20

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?

 Yes  No

Transaction Monitoring

21

Does the FI have a monitoring program for suspicious or unusual activity that covers funds transfers and monetary instruments (such as travelers cheques, money orders, etc.)?

 Yes  No

AML Training

22

Does the FI provide AML training to relevant employees that includes identification and reporting of transactions that must be reported to government authorities, examples of different forms of money laundering involving the FI’s products and services and internal policies?

 Yes  No

23

Does the FI retain records of its training sessions including attendance records and relevant training materials used?

 Yes  No

24

Does the FI have policies to communicate new AML related laws or changes to existing AML related policies or practices to relevant employees?

 Yes  No

25

Does the FI employ agents to carry out some of the functions of the FI and if so does the FI provide AML training to relevant agents that includes identification and reporting of transactions that must be reported to government authorities, examples of different forms of money laundering involving the FI’s products and services and internal policies to prevent money laundering?

 Yes  No