theWolfsberg

Group

The Wolfsberg Group Anti-Money Laundering Questionnaire v.2/2008/English

Financial Institution Name: BANCO DE LA REPÚBLICA

Location: Cra 7 No 14-78 / Bogotá - Colombia~

Anti-Money Laundering QuestionnaireIf you answer "no" to any question, additional information can be suppliedat the end of the uestionnaire.

'fi'.{iifiii¡lCI'A;1iIJlifl¡¡Ji~~j;'lh:7i~lt~§i~ñ'B~j:j1:t!l.~ftl(g~'f!fí~l~1~~*€~Jilf;;~t~~~~N~1. Is the AML compliance program approved by.the FI's board or a VES

senior committee?2. Does the FI have a legal and regulatory compliance program VES

that includes a deslqnated officer that is responsible forcoordinatin and overseein the AML framework?

3. Has the FI developed written polieies doeumenting the VESproeesses that they have in place to prevent, deteet and reportsus icious transaetions?

4. In addition to inspections by the government VESsupervisors/regulators, does the FI c1ient have an internal auditfunet ion or other independent third party that assesses AML

olicies and ractices on a re ular basls?5. Does the FI have a policy prohibiting aceounts/relationships VES

with shel! banks? (A shell bank is defined as a bankincorporated in a jurisdiction in which it has no physicalpresence and which is unaffiliated with a regulated financial

rou .6 . Does the FI have polleies to reasonably ensure that they will VES

not conduct transactions with or on behalf of shell banksthrou h an of its accounts or roducts?

7. Does the FI have policies covering relationsh ips with Politíeally NOEx osed Persons PEP's their famil and close associates?

8. Does the FI have record retention proeedures that comply with VESa lieable law?

9. Are the FI's AML policies and practices being applied to al! VESbranehes and subsidiaries of the FI both in the home country

1i~8liR1«~ii~~.I¡¡~¡i~Jir~_fil%~é$~~~NO~10. Does the FI have a risk-based assessment of it s customer base VES

and the ir transactions?11. Does the FI determine the appropriate level of enhanced due VES

diligence neeessary for those categories of customers andtransactions that the FI has reason to believe pose ahel htened risk of iIIicit act ivities at or throu h the FI?. 'c' ~~~:.

lJ9§ll~"12. Has the FI implemented processes for the Identificat ion of those VES

customers on whose behalf it maintains or operates accounts orconduets transactions?

The Wolfsberg Group consists of the following leading Inte rnat lonal financial insti t utlons: Banco Santander, Bank of Tokyo-btltsubishlUFJ, Barclays, Citigroup, Credit Sulsse, Deutsche Bank, Goldman Sachs, HSBC, JP Morgan Chase, Soclété Générale and UBS whlchaim to develop financial services Industry standards , and related products, for Know Your Customer, Antl -Money Launderlng andCounter Terrorist Flnanclnq polic ies.

theWolfsberg

Group

The Wolfsberg Group Antl-Money l aundering Questionnalre v.2/2008/English

13. Does the FI have a requirement to eolleet information regard ing I VESits eusto mers' business aet ivities?

14. Does th e FI assess its FI eustomers' AML oolieies or oraetices? I VES15. Does the Fl have a process to review and, where appropriate, I VES

update customer informat ion relating to high risk c1ientinformation?

16. Does the FI have procedures to establísh a record for each riew I VEScustomer noting their respective identification documents and'Know Your Customer' Information?

17. Does the FI complete .a risk-based assessment to understand the I VESnormal and exoected transaetions of its eustomers?

18. Does the FI have policies or practices for the identification and I VESreporting of transactions that are required to be reported to theauthorities?

19. Where cash transaction reporting is mandatory, does the FI have I VESprocedures to identify transaetions structured to avoid suchobliaations?

20. Does the FI sereen customers and transactions against Iists of I VESpersons, entit ies or eountries issued by government/competentauthorities?

21 . Does the FI have policies to reasonably ensure that it only I VESoperates with correspondent banks that possess licenses tooperate In their countrles of oriain?

~W.~~~~¡1flf?lfj§~glqa!~M91l1JJ)Jil}j22. Does the FI have a monitoring program for unusual and

potentially suspicious activity that eovers funds transfers andmonetary instruments such as travelers checks, money orders,etc?

23. Does the FI prov lde AML training to relevant employees thatincludes:

• Identification and reporting of transactions that must be reportedto government authorities.

• Examples of different forms of money laundering involving theFI's prod uets and services.

• Interna1 oolícles to orevent monev launderin.....24. Does the FI reta in reeords of its training sessions lncludíng I VES

attendance records and relevant trainina materials used?25. Does the FI communicate new AML related laws or changes to I VES

existina AML related oollcles or oractlces to relevant emolovees?26. Does the FI employ third parties to carry out some of the l iNO

functions of the FI?27 . If the answer to question 26 is ves, does the FI provide AML

training to relevant third parties that includes:Identification and reporting of transactions that must be reportedto government authoríties.

• Examples of different forms of money 1aundering involving theFI's products and serviees.Internal oolicies to orevent monev launderin... .

The Wolfsberg Group consists of the follow lnq leading international financiallnstitutions: Banco Santander, Bank of Tokyo-MitsublshlUF) , Barclays, Cit igroup, Credit su tsse, Deutsche Bank, Goldman Sachs, HSBC, JP 1>1organ Chase, Société Générale and UBS whichaim to develop financial services industry standards, and related products, for Know Your Customer, Anti-Money laundering andCounter Terrorist Financlng policies.

2

theWolfsberg

Group

The Wolfsberg Group Anti-Money Laundering Questio nnaire v.2/2008/English

Space for add itional informat ion :(P/ease indicate which question the informat ion ts referring to.)

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Name: GERMAN CAMACHO ALVAREZTitle: COMPLIANCE OFFICER

Slgnature: ~~'v~~

Oate:04/03/2D13

The Wolfsberg Group consists of the followinq leading interna tional financial institutions: Banco Santander, Bank of Tokyo -MitsubishiUF), Barclays, Citigroup, Credi t Suisse, Deutsche Bank, Goldman Sachs, HSBC, JP Morgan Chase, Société Généra le and UBS whlchaim to develop financial servi ces industry standards, and related produces, for Know Your Customer, Anti-Money Launder ing andCounter Terrorist Financing pol icies.

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