2.21 Does the FI review the AML/CFT controls of correspondent banks prior Yes No to opening an account for them? 2.22 Does the FI have procedures in place to identify transactions structured Yes No to avoid large cash reporting requirements? 2.23 Is the FI permitted by local regulations to share customer identification Yes No data with correspondents should they request this? If so would you be willing to share this if requested by us in the event of Yes No a legitimate need arising? 3. Risk Assessment 3.1 Does the FI have a risk assessment of its customer base and their Yes No transactions? 3.2 Does the FI determine the level of enhanced due diligence necessary Yes No 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 3.3 Does the FI perform Enhanced Due Diligence (EDD) when the risks are Yes No increased? 4. Customer Due Diligence, and enhanced Due Diligence 4.1. Does the FI have procedures to establish a record for each new Yes No customer noting their respective identification documents and Due Diligence” information? “Customer 4.2 Has the FI implemented processes for the identification of those Yes No customers on whose behalf it maintains or operates accounts or conducts transactions? If yes please provide a brief description of the process adopted: Passports or other government issued photo ID is reviewed, addresses verified, clients screened for sanctions, PEP connections, adverse media, and bankruptcy. Private customers and the beneficiaries of small micro enterprises or charities are checked against the CIFAS website. 4.3 Does the FI obtain information on the customer’s principle purpose and Yes No intended nature of the business relationship? 4.4 Does the FI have a requirement to collect information regarding its Yes No customers’ ongoing business activities? 4.5 Does the FI conduct ongoing monitoring of the business relationship? Yes No 4.5 Does the FI assess its customers AML policies or practices? Yes No ‘ 4.6 Does the FI have a process to review and appropriate update Yes No customer information relating to high risk client information? If yes please advise the date upon which the most recent review was undertaken and when a further review is due: Reviewed 2016 next review due March 2017
2.21 Does the FI review the AML/CFT controls of correspondent banks prior to opening an account for them? Yes No 2.22 Does the FI have procedures in place to identify transactions structured to avoid large cash reporting requirements? 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 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 a brief description of the process adopted: Passports or other government issued photo ID is reviewed, addresses verified, clients screened for sanctions, PEP connections, adverse media, and bankruptcy. Private customers and the beneficiaries of small micro enterprises or charities are checked against the CIFAS website. Yes No 4.3 Does the FI obtain information on the customer’s 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 4.5 Does the FI assess its customers ‘ AML policies or practices? Yes No 4.6 Does the FI have a process to review and appropriate update customer information relating to high risk client information? If yes please advise the date upon which the most recent review was undertaken and when a further review is due: Reviewed 2016 next review due March 2017 Yes No