General AML Policies, Practices and Procedures
1. Are there laws / regulations designed to prevent and deal with money laundering and terrorist financing in the country of incorporation of your company or institution? If yes, please list the names of the relevant laws.
2. Has your institution developed written policies and procedures to prevent detect and report suspicious transactions/terrorist financing activities?
3. Does your AML/CFT policy meet the requirement of local laws and the FATF standards?
4. Does these laws and regulations prohibit your institution from conducting business with or on behalf shell companies?
5. Is your AML/CFT policy approved by the board of your institution or by a senior committee?
6. Does your policy require you to identify the source of your customers’ funds or income?
7. Does your institution collect information regarding its customers’ business activities and assess its customers’ AML policies or practices?
8. Is your institution subject to the supervision of any regulatory authority? If yes, please give the name of the supervisory/regulatory authority.
9. Please give the name of the authority to which you must report in case of a suspicion of money laundering and terrorist financing.
10. In addition to inspections by the government supervisors/regulators, does your institution have an internal audit function or other independent third party that assesses AML policies and practices on a regular basis?
11. Does your Entity have an established Anti-bribery and corruption Policy (If yes, please provide a copy)
12. Does your institution have policies to cover relationships with Politically Exposed Persons (PEPs), their families and close associates?
13. Does your institution have appropriate record retention procedures pursuant to applicable laws? If yes, please state the period of time for which records are kept.
Risk Assessment
14. Does your institution have a risk-based assessment of customer base and their transactions?
15. Does your institution determine the appropriate level of enhanced due diligence necessary for those categories of customers and transactions that your institution has reason to believe pose a heightened risk of illicit activities?
Know Your Customer, Due Diligence and Enhanced Due Diligence
16. Does your institution require the verification of identification information for all customers and counterparties (individuals or entities) at the establishment of the relationship? (such as; name, nationality, address, telephone number, occupation, age/date of birth, number and type of valid official identification, as well as the name of the country/state that issued it)?
17. Does your institution have procedures to establish a record for each new customer that contains their respective identification documents and ‘Know Your Customer’ information?
18. Does your customer identification program require that enhanced due diligence be conducted regarding certain customers that may present a heightened level of money laundering and terrorist financing risk to your institution, such as international private banking and correspondent banking customers, or customers from high risk money laundering and terrorist financing jurisdictions?
19. Does your institution have a periodic process to review and, where appropriate, update high-risk customer information?
Reportable Transactions and Prevention and Detection of Transactions with Illegally Obtained Funds
20. Does your institution have policies or practices for the identification and reporting of transactions that are required to be reported to the authorities?
Transaction Monitoring
21. Does your institution have a monitoring program for unusual and potentially suspicious activities that could expose your institution to any ML/FT risks?
22. Does your institution filter payments against relevant United Nations sanctions lists?
AML Training
23. Does your Institution provide AML/CTF/Sanctions & Embargoes 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 institution’s products and services; International, national, and internal policies to prevent money laundering. If yes, how frequent are these trainings?
24. Does your institution retain records of its training sessions including attendance records and relevant training materials used?
25. Does your institution have policies to communicate new AML/CTF/Sanctions & Embargoes related laws or changes to existing AML/CTF/Sanctions & Embargoes related policies or practices to relevant employees?
26. Does your Institution employ third parties to carry out some of the AML/CFT/ Sanctions & Embargoes functions of the institution?