Questionnaire for Anti-money Laundering and Combating the Financing of Terrorism by Lending Institutions
I. General Provisions of Anti-money Laundering and Combating the Financing of Terrorism / Yes / No1 / Do banks in the country of incorporation of your bank act as bodies of execution of the laws on anti-money laundering and combating the financing of terrorism (hereinafter, ALCFT)?
2 / Does any state supervisory/regulatory body supervise application of the ALCFT requirements by a lending institution?
If yes, please, specify the name of such a body:
2.1. ______
3 / Has your bank developed the internal control procedures for the ALCFT purposes and the implementation program in accordance with domestic laws and other regulations?
4 / Has your bank assigned a special officer responsible for implementation of the internal control procedures for the ALCFT purposes?
5 / In addition to inspections made by state supervisory bodies, do the internal audit (control) service and external audit company inspect the ALCFT measures in your bank?
6 / Does your bank have the policy for prohibition of correspondent relations with any banks which do not cooperate or take measures for the ALCFT purposes?
7 / Has your bank determined the terms and procedures for storing of information obtained in implementation of the internal control procedures in ALCFT?
8 / Does your bank have the requirement of the Parent Company, according to which the bank’s policy and practical implementation of the ALCFT measures apply in all its branches and affiliates both within and outside the country of the Parent Company (if available)?
9 / Have any regulatory authorities applied the enforcement actions to your bank due to failure to execute the laws on anti-money laundering and combating the financing of terrorism for the last five years?
If yes, please, specify the details:
9.1. ______
II. Implementation of the ‘Know Your Customer’ Principle and the Customer Research Procedure / Yes / No
10 / Does your bank identify and research customers and their representatives, determine and identify the target beneficiaries?
11 / Does your bank open accounts for anonymous owners?
12 / Does your bank have the requirement to collect information on the purpose of financial and economic activities, financial position and business reputation of customers?
13 / Does your bank collect and assess information on implementation of the ALCFT measures by customers?
14 / Has your bank developed the questionnaires (records) for persons to be identified?
15 / Does your bank have the procedure for assessing the risk of customer transactions for the purposes of money laundering and financing of terrorism?
16 / Does your bank identify a person which does not have any account with the bank when making a cash transaction under his/her passport/ other identity document, and keep the document copy in the bank?
17 / Does your bank determine the required advanced due diligence for relevant customer categories and transaction groups which, in the opinion of your bank, are related to an increased risk of making illegal transactions in your bank or through your bank?
18 / Has your bank established the procedures governing the relations with public officials?
III. Implementation of the Internal Control Procedures Aimed at Protecting a Lending Institution from Penetration of Criminal Proceeds / Yes / No
19 / Has your bank developed the transaction monitoring procedure that allows monitoring the signs of unusual transactions?
20 / Does your bank apply automated systems to monitor settlement documents (data on a payer and a payee) in order to identify transactions of persons or entities which are known for or suspected of involvement in terrorist activities, before actual execution of a transaction?
21 / Does your bank support correspondent relations with any banks incorporated in the countries or territories that provide for preferential tax treatment and/or do not provide for disclosure and delivery of information when making financial transactions (offshore zones)?
If yes, please, specify such correspondent banks:
21.1. ______
21.2 ______
22 / Does your bank have any non-resident banks among its correspondents or counterparties, which do not have standing supervisory bodies in the territories of countries of incorporation?
23 / Does your bank have correspondent relations with any banks in respect of which there is information that their accounts are used by banks which do not have standing supervisory bodies in the territories of countries of incorporation?
IV. Training under the Program of Anti-money Laundering and Combating the Financing of Terrorism / Yes / No
24 / Does your bank train and examine its employees and agents (if any) on anti-money laundering and combating the financing of terrorism, including identification and reporting of transactions to be supervised, familiarization with standard schemes of money laundering using your bank’s products and services, as well as research of the internal control procedures for the ALCFT purposes?
25 / Does the internal audit (control) service of your bank inspect the procedures for storing the (advanced) training documents?
26 / Does your bank have the procedures under which the bank’s employees are notified of any changes in the laws, regulations or internal control procedures for the purposes of anti-money laundering and combating the financing of terrorism?
______/______/
(position) (signature) Surname, name, patronymic
L.S.
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