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