Last Version update: March 2010
Questionnaire regarding
Anti-Money Laundering Policies, Procedures and Practices
Financial Institution’sName:_JSC “DELTA BANK”______
Address / Country of Domicile __36-B, Shchorsa Str., 01133, Kyiv,Ukraine______
Please provide a response to each question below concerning your Financial Institution’s practices related to the monitoring, identification, and reporting of suspicious transactions.
1.) Yes_X_/No__Does your financial institution have written policies and procedures in place regarding anti-money laundering and know-your-customer practices?
- Yes_ X__/No___ Does the policy reflect a regular process for your financial institution to obtain information about its customers that relate to money laundering risk, including name, address, type of business and anticipated nature of transactions between the customer and your financial institution.
- Yes_ X/No___ Does the policy reflect a regular process to identify categories of suspicious activity by monitoring customer transactions?
- Yes_ X_/No___ Does the policy reflect a process to notify appropriate government/supervisory authorities regarding suspicious activity?
- Yes_ X_/No___ Does the policyanticipate a regular audit or review by persons whose principal function is to audit or review your financial institution, to determine that the AML program in place is substantially functioning as designed?
- Yes_ X_/No___ Does the policyreflect an AML training program designed to deliver information to your employees who would reasonably be expected to encounter potentially suspicious activity?
- Yes_X_/No___ Does the policyrequire your financial institution to decline business with excessive money laundering risk, and to carefully track high risk accounts to protect against money laundering?
2.) Yes_X_/No___ Does your financial institution have a Designated Anti-Money Laundering Compliance Officer?
a. Name of responsible AML Officer: _Ms. Svitlana Kinberg, Deputy Chairwoman of the Board of Diectors__
3.) Yes_X/No___Does yourfinancial institution have policies and procedures prohibiting your bank from providing services for shell banks?
4.) Yes_X/No___Does your financial institution have a monitoring process in place to detect suspicious transactions?
a.Is this process manual or automated? __automated______
- What types of transactions do you monitor (e.g. large value transactions (cash withdrawals/ cash deposits)? _large value transactionsof any kind as stipulated by the NBU and screening against blacklists______
Financial Institution’s Name:_JSC “DELTA BANK”______
Address / Country of Domicile __36-B, Shchorsa Str., 01133, Kyiv,Ukraine______
5.) Yes_X/No___ Does your financial institution follow the anti-money laundering policies established by your country’s Central Bank?
- If yes, would we be able to obtain an English version of your Central Bank’s anti-money laundering policies? _no,only Ukrainian language is available now______
6.) Yes_X/No___Does your financial institution provide Correspondent Banking services to other financial institutions?
a. Yes_X/No___ In USD?
b.Yes_X/No___ In EURO?
c.Yes_/No_XIn STERLING?
d.Yes_X/No___ In Local Currency?
e. Yes_X_/No___ If yes to any of the above, do you review your customers anti-money laundering practices before adopting that entity as a client?
7.) Yes___/NoX Does your financial institution offer Payable-Through-Account (“PTA”) services or accounts to any of your customers
a. If yes, please provide the policies and procedures as well as a description as to the circumstances that such services or accounts are offered.
______
b. By signing this questionnaire, ______JSC “DELTA BANK”_____(FI’s name) confirms that its account with DB is and will not be used as a PTA account.
c. By signing this questionnaire, ___JSC “DELTA BANK”____ (FI’s name) confirms that its account with DB is and will not be used, nor will it submit to DB any transaction, in connection with any PTA account or service that _____JSC “DELTA BANK”_____(FI’s name) offers to its customers.
(Company Stamp)
______
Date / Place Name / Title and FunctionName / Title and Function
Note:
Payable Through Accounts are defined as “establishing or managing accounts in the institution’s name or for third-party institutions which customers may access independently to carry out their own transactions” according to section 25h of the German Banking Act and are prohibited
Page 1 of 2