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.