AML CTF Questionnaire for Banks & NBFIs

AML CTF Questionnaire

This questionnaire is required to be filled out by any/all of the following:

  • Non-Banking Financial Institutions
  • Correspondent Banks
  • Currency Exchange Companies
  • Money Transfer Operators
  • Money Services Business
Institution Details  Your Reply
Name of Bank
Registered Name
Registered Address
Mailing / Street Address
Web Address
Jurisdiction under which incorporated

(Please provide copy of incorporation certificate)

Banking license #

(Please provide copy of license)

Number of Branches (Local/Foreign)
Name of External Auditors
Name of the Central Bank/regulatory body
Main banking activities
Name of Members of the Board of Directors
  Does your institution have a “Physical Presence”?

  Your institution is an affiliate of depository institutions, credit union, or a foreign bank that maintain a physical presence at the place where it employs one or more persons on a full time basis & maintains operating records related to it banking activities?

The purpose of the account (If maintained)
Management / Ownership Structure
Are share publicly held or privately owned
Is it traded on any Stock Exchange
Full details of any natural or legal persons, partnership or trust holding 25% or more of the voting rights
Anti Money Laundering Legislation, Policies & Procedures Please complete the following questions by indicating Yes/No and comments thereon where appropriate:
Is money laundering / terrorism Financing considered in your country as crime?
Has your country established laws / regulations concerning AML/CTF/KYC
Does your country’s regulatory body (Central Bank) require all financial institutions to have anti money laundering (AML) & Know Your Customer (KYC) procedures?
Is your institution subject to such laws/regulations
Has your institution established a conformity program that contains AML/CTF/KYC policies and procedures, according to internal & international laws, rules and standards?

(Please provide a copy of these documents issued by your Bank).

In case your institution does not have such regulations, are they planned to be introduced? Please indicate the estimated date of its implementation
Has your bank developed an Internal Audit function in order to test the system for prevention of money laundering and terrorism financing?
Are the AML/CTF/KYC policies and procedures applicable to your home entities also applied to your foreign branches?
Is implementation of AML/CTF/KYC policies and procedures monitored on a permanent basis?
Has your institution established employees training program for recognizing the transactions related to AML and identifying the measures that should be taken?
Does your institution have a policy of protecting employees who report any suspicious transactions
Condition of the bank regulation and supervision in the correspondent’s country.
Relationship with only those banks which have effective customer acceptance and KYC policies and are effectively supervised by the relevant authorities.
AML / KYC Policies & Procedures
Does your AML/CTF/KYC policies and procedures require:

  Recognizing the true identity of customers and checking their legitimacy before transacting any business with them?

  Identifying any third party that makes use of correspondent banking services?

  Monitoring client activity to detect suspicious activity and due diligence?

  Reporting suspicious activities and transactions to the appropriate AML/CTF/KYC authorities?

  Keeping all the records related to customer identification and their transactions? For how long?

Does your AML/CTF/KYC policies and procedures allow to:

  Open or maintain of anonymous accounts or numbered accounts?

  Conduct business with the banks having no Physical presence in any country i.e SHELL BANKS

  Maintain currently accounts for SHELL BANKS?

Has your institution been subject to any investigation, indictment, conviction or civil enforcement action related to money laundering and terrorism financing? If so, please provide details.
Does your institution comply with FATF recommendations?
Does your institution provide services to offshore Banks, Internet Banks type institutions or banks located in high risk area, as per FATF recommendations?
Does your bank allow direct use of the correspondent account by third parties to transact business on their behalf (i.e. payable through accounts)?
Are you a downstream correspondent clearer? (resp. if you are a downstream clearer, kindly supply a list of your relevant counterparties)
Transaction Monitoring
Does your institution have monitoring programs for identifying the transactions (SWIFT, telegraphic transfers) related to persons / entities suspected of ML/FT, as mentioned in the official lists (e.g. OFAC, UN, EU, or any local authority?)
Has your institution implemented any software to assist in the monitoring of transactions?
CONTACT DETAILS: (Please provide details & title regarding who completed this questionnaire
Has your institution appointed a Compliance Officer for AML/CTF/KYC
If so, please give the name and title of Compliance Officer in your institution, his/her email, address, Phone number, Fax number for future references
Authorized Signature:
Name
Title
Phone:

Fax:

Email:

Mobile:

Alternate Phone:

 


 

You can find more resources pertaining to AML / CTF Questionnaire on the FAFT-GAFI Website.