Annual Anti-Money Laundering Questionnaire (based on the Wolfsberg Group guidance)
Sent by Persia International Bank Plc London (PIB), to all of its correspondent banks (referred to in this questionnaire as Financial Institutions (FI)
Please note that in the below questionnaire there is frequent reference to the submitter being a FI (i.e. Financial Institution), and that the term encompasses banks as well as other financial institutions.
Ownership/shareholder and supervisory information1.1 / Is the FI a private company? / Yes / No
1.2 / Is the FI a public/state owned company? / Yes / No
1.3 / Is the FI part of a group?
If the answer is yes then please name the group below: / Yes / No
1.4 / Is the FI Quoted on a stock exchange?
If the answer is yes then please name the stock exchange below: / Yes / No
1.5 / Is the FI resident in the country of incorporation?
1.6 / Please name all shareholders and any beneficial ownersowning, controlling or having voting rights of more than 10% of the FI (either directly or indirectly).
For each shareholder/beneficial owner please state the following:
Name:
address:
Percentage of ownership:
Kind of ownership:
(Owning/controlling/ voting rights)
1.7 / Have there been any considerable changes in beneficial ownership over the past 12 months?
If the answer is yes then please provide the details below: / Yes / No
1.8 / For each member of the Board of Directors please state the following:
Full Name:
Date of Birth:
Nationality: / Yes / No
1.9 / Are any Politically Exposed Persons (PEPS) either beneficial owners or members of senior management (e.g. Chairman, CEO, CFO).
If yes please provide their names and positions below
1.10 / Has there been any considerable change in the Board of Directors during the past 12 months?
If the answer is yes then please provide details and reasons below: / Yes / No
1.11 / Please name below the supervisory authority of the FI:
1.12 / Is the FI subject to an external audit?
If the answer is yes then please provide the auditor’s name and address below: / Yes / No
- General AML/CTF/Sanctions Policies
2. 1 / Is the AML/CTF compliance programme approved by the FI’s board or a senior committee?
If yes please specify below, board or senior committee and date last approved: / Yes / No
2.2 / Does the FI have a legal and regulatory compliance programme that includes a designated officer that is responsible for coordinating and overseeing the AML framework?
If yes please specify below the name and position of designated officer:
Name:
Position:
Telephone Number:
e. mail address: / Yes / No
2.3 / Has the FI developed written policies documenting the processes that are in place to prevent, detect and report suspicious transactions?
If yes please specify below the date upon which the policy was reviewed and approved and when a future review is due: / Yes / No
2.4 / Do the FI’s policies and procedures apply to all branches and subsidiaries of the FI both inside and outside its country of incorporation? / Yes / No
2.5 / Has the FI’s country of registration established laws designated to combat money laundering /terrorist financing and adhere to financial sanctions? / Yes / No
2.6 / Is the FI subject to subject to such laws and legislation?
Name of government agency responsible for applying AML enforcement action. / Yes / No
2.7 / Has the FI written internal policies and procedures which ensure compliance with the obligations under the existing national legislation on preventing money laundering, counter terrorist financing and any applicable financial sanctions? / Yes / No
2.8 / In addition to inspections by the government, supervisors/regulators, does the FI have an internal audit function/ Compliance monitoring programme or other third party that assesses AML policies and practices on a regular basis?
(Continued from page 1).
If yes please specify below the date of the last audit and approved and when a future review is due: / Yes / No
2.9 / Are the FI’s policies procedures compliant with FATF recommendations? / Yes / No
2.10. / Are the FI’s AML/CTF financial sanctions controls monitored to ensure continuing effectiveness? / Yes / No
2.11 / Does the FI have a policy prohibiting accounts/relationships and services with shell banks? (a shell bank is defined as a bank which has no physical presence and which is unaffiliated with a regulated financial group)
If yes please specify below when the policy was last reviewed and approved and when a future review is due: / Yes / No
2.12 / 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?
If yes please specify below when the policy was last reviewed and approved and when a future review is due: / Yes / No
2.13 / Does the FI have record retention procedures which comply with applicable law?
If yes please specify below the retention period and the applicable law: / Yes / No
2.14 / Does the FI allow direct use of the correspondent accounts by third parties to transact business on their own behalf? / Yes / No
2.15 / Does the FI provide services to unregulated Money Service Bureaus (MSBs) or virtual currency providers / Yes / No
2.16 / Does the FI’s home country have laws preventing the establishment of anonymous accounts? / Yes / No
2.17 / Does the FI permit transactions conducted by non-established or walk in customers?
If yes does the FI have identification requirements for such customers and a threshold for the transactions value? / Yes / No
2.18 / Does the FI provide services to other FIs listed outside of your country? / Yes / No
2.19 / Does the FI provide services to the following types of FI? If yes please provide a list of these
Offshore Banks Yes/No
Internet Banks Yes/No
Money Service Bureaus Yes/No
Internet gambling companies Yes/No
Nested Accounts Yes/No
For any questions answered “Yes” please state below whether there are policies and procedures to mitigate potential; risks associated with these higher risk customer types and explain how the FI mitigates these risks
2.20 / Does the FI act as a downstream correspondent clearer?
If yes state below which type of financial institutions it acts for: / Yes / No
2.21 / Does the FI ensure that it only deals with correspondent banks that possess licences to operate in the country of origin? / Yes / No
2.22 / Does the FI review the AML/CFT controls of correspondent banks prior to opening an account for them? / Yes / No
2.23 / Is the FI permitted by local regulations to share customer identification data with correspondents should they request this?
If so would you be willing to share this if requested by us in the event of a legitimate need arising? / Yes
Yes / No
No
3. Risk Assessment
3.1 / Does the FI have a risk based assessment of its customer base and their transactions? / Yes / No
3.2 / Does the FI determine the 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
3.3 / Does the FI perform Enhanced Due Diligence (EDD) when the risks are increased? / Yes / No
4. Customer Due Diligence, and enhanced Due Diligence
4.1. / Does the FI have procedures to establish a record for each new customer noting their respective identification documents and “Customer Due Diligence” information? / Yes / No
4.2 / Has the FI implemented processes for the identification of those customers on whose behalf it maintains or operates accounts or conducts transactions?
If yes please provide below a brief description of the process adopted: / Yes / No
4.3 / Does the FI obtain information on the customers’ principle purpose and intended nature of the business relationship? / Yes / No
4.4 / Does the FI have a requirement to collect information regarding its customers’ ongoing business activities? / Yes / No
4.5 / Does the FI conduct ongoing monitoring of the business relationship? / Yes / No
4.6 / Does the FI assess its customers ‘ AML policies or practices? / Yes / No
4.7 / Does the FI have a process to review and where appropriate update customer information relating to high risk client information?
If yes please advise below the date upon which the most recent review was undertaken and when a further review is due: / Yes / No
4.8 / How does the FI take action to identify the beneficial ownership of customers and their true identity? / Yes / No
4.9 / How does the FI conduct enquiries in order to establish source of wealth and funds acquired by its customers? / Yes / No
4.10 / Does the FI complete a risk-based assessment to understand the normal and expected transactions of its customers? / Yes / No
4.11 / Does the FI keep customer identification files as well as business correspondence and record them for a specific period of time?
If yes please specify the retention period / Yes / No
4.12 / Does the FI have policies covering relationships with Politically Exposed Persons (PEPs) their family and close associate?
If yes please specify below when the policy was last reviewed and approved and when a future review is due: / Yes / No
4.13 / Does the FI undertake enhanced due diligence measures (EDD) in cases where the customer has not been physically present for identification purposes? / Yes / No
4.14 / Does the FI undertake EDD measures in respect of cross-border correspondent banking relationships and other similar relationships with respondent institutions from third countries? / Yes / No
4.15 / Does the FI undertake CDD measures when carrying out occasional transactions of significant amounts?
If yes please indicate what these measures comprise / Yes / No
4.16 / Does the FI employ agents to carry out some of its functions?
If yes does the FI provide relevant AML training to relevant agents that includes identification and reporting of suspicious transactions? / Yes / No
5. Reportable Transactions and prevention and detection of transaction with illegally obtained funds
5.1 / Does the FI have policies or practices for the identification of transactions that are required to be reported to the authorities?
If yes please specify below when the policy was last reviewed and approved and the appropriate authority to which such report would be submitted: / Yes / No
5.2 / Where cash transaction reporting is mandatory, does the FI have procedures to identify transactions structured to avoid such obligations?
If yes please specify below when these procedures were last reviewed and approved and when a future review is due:
Please also specify if applicable, as to which authority the transaction would be reported:
If the answer to question 5.2 is no please confirm whether this is because it is not mandatory to report cash transactions:
. / Yes / No
5.3 / Does the FI screen customers and transactions against list of persons, entities or countries issued by government or other competent authorities?
If yes please specify below the name of that competent authority: / Yes / No
5.4 / 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?
If yes please specify below the date that the policy was last reviewed and approved and when a future review is due: / Yes / No
5.5 / Does the FI adhere to the Wolfsberg Transparency Principles and the appropriate usage of the SWIFT MT 202/202COV and MT 205/205 COV formats? / Yes / No
5.6 / Does the FI comply with FATF recommendation requiring that full originator and beneficiary information is included in all payments it makes / Yes / No
6. Transaction Monitoring
6.1 / Does the FI have a monitoring programme for unusual and potentially suspicious activity that covers fund transfers and monetary instruments such as travellers cheques, money orders etc? / Yes / No
7. AML Training
7.1 / Does the FI provide AML training to relevant employees that includes:
- Identification and reporting of transactions that must be reported to the authorities
- Examples of different forms of money laundering involving the FI’s products and services
- Internal policies to prevent money laundering; and is
- Binding upon management and staff
7.2 / Does the FI retain record of its training sessions including attendance records and relevant training materials used? / Yes / No
7.3 / Does the FI communicate new AML related laws or changes to existing AML related policies or practices to relevant employees? / Yes / No
General Questions
8.1 / Has the FI had any regulatory or criminal enforcement actions relating from violation of AML law or regulation in the past five years?
If yes please explain nature of same below: / Yes / No
8.2 / Has the FI to your knowledge been subject to any investigation, indictment, or criminal action relating to terrorist financing in the past five years.
If yes please explain nature of same below: / Yes / No
Signed By:
Date:
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