theWolfsberg

Group

Financial Institution Name: Prime Bank Limited

Location: Adamjee Court, Annex Building-2,ll9-120 Motijheel Com. AreaDhaka 1000, Bangladesh

Iat the end of the ouestionnaire.I, General AML Polides,'Pra'ctices and Procedurest

1. Is the AML compliance program approved by the FI's board or a

senior committee?

Yes

lY/I

NolNoI

I

2. Does the FI have a legal and regulatory compliance programthat includes a designated officer that is responsible forcoordinatinq and overseeinq the AML framework?

Vt/ No

3. Has the FI developed written policies documenting theprocesses that they have in place to prevent, detect and repoftsuspicious tra nsactions?

Y\/ No

4. In addition to inspections by the governmentsupervisors/regulators, does the FI client have an internal auditfunction or other independent third party that assesses AMLpolicies and practices on a reqular basis?

Y\/ No

5. Does the FI have a policy prohibiting accounts/relationshipswith shell 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 financialqroup. )

Y\/ No

6. Does the FI have policies to reasonably ensure that they willnot conduct transactions with or on behalf of shell banksthrouqh anv of its accounts or products?

Y\/ No

7. Does theExoosed

FI have policiesPersons (PEP's),

covering relationships with Politicallytheir familv and close associates?

Y\/ No

B. Does the FI have record retention procedures that comply withapplicable law?

Y\/ No

9. Are the FI's AML policies and practices being applied to allbranches and subsidiaries of the FI both in the home countryand in locations outside of that jurisdiction?

II. RiikAssess ment10. Does the FI have a risk-based assessment of its customer base

and their transactions?

Y\/

YesY\/

No

NoNo

11. Does the FI determine the appropriate level of enhanced duediligence necessary for those categories of customers andtransactions that the FI has reason to believe pose aheiqhtened risk of illicit activities at or throuqh the FI?

III. xnoiv Your Customer, Due Diligen"" "hd

EnhancedDue DiliEence' ::":""';.':',t'"'", ' '

12. Has the FI implemented processes for the identification of thosecustomers on whose behalf it maintains or operates accounts orcond ucts tra nsactions?

Y\/

Yes

Y\/

No

No

No

The Wolfsberg Group Anti-Money Laundering Questionnaire v .2/20081 English

The Wolfsberg Group consists of the following leadlng international financial institutions: Banco Santander, Bank of Tokyo-lYitsubishiLJFl, Barclays, Citigroup, Credit Suisse, Deutsche Bank, Goldman Sachs, HSBC, JP Morgan Chase, Soci6t6 G6ndrale and UBS whichalm to develop financial services industry standards, and related products, fo. Know Your Customer, Antj-lvoney Laundering andCounter Terrorist Financing policies.

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ffiffiffi

theWolfsberg

Gro$p13. Does the FI have a requirement to collect information regarding

its customers' business activities?Vr/ No

14. Does the FI assess its FI customers'AML policies or practices? Vt/ No15. Does the FI have a process to review and, where appropriate,

update customer information relating to high risk clientinformation?

Vr/ No

16. Does the FI have procedures'to establish a record for each newcustomer noting their respective identification documents and'Know Your Customer' information?

Y\/ No

17. Does the FI complete a risk-based assessment to understandthe normal and expected transactions of its customers?

Y\/ No

IV. Repoftable Transactions,and Preven,tion andDetectiOn' of Transatctions with lllegally'Obtained Funds

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

Yes No

Y\/ lruo

19. Where cash transaction reporting is mandatory, does the FIhave procedures to identify transactions structured to avoidsuch oblioations?

Y\/ No

20. Does the FI screen customers and transactions against lists ofpersons, entities or countries issued by government/competentauthorities?

Y\/ No

ensure that it onlypossess licenses to

21. Does the FI have policies to reasonablyoperates with correspondent banks thatoperate in their countries of oriqin?

Y\/ No

22, Does the FI have a monitoring program for unusual andpotentially suspicious activity that covers funds transfers andmonetary instruments such as travelers checks, money orders,etc?

v. YesY\/

NoNo

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

. Identification and reporting of transactions that must bereported to government authorities.

. Examples of different forms of money laundering involving theFI's products and services.

. Internal oolicies to orevent monev launderino.

YesY\/

NoNo

sessions includingmaterials used?

24. Does the FI retain records of its trainingattendance records and relevant traininq

Y\/ No

25. Does the FI communicate new AML related laws or changes toexisting AML related policies or practices to relevantemployees?

Y\/ No

26. Does the FI employ third pafties to carry out some of thefunctions of the FI?

Yo N

\/27.If the answer to question 26 is yes, does the FI provide AML

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

reported to government authorities.. Examples of different forms of money laundering involving the

FI's products and services.. Internal policies to orevent monev launderino.

Yo No

The Wolfsberg Group consists of the following leading international financial institutions: Banco Santander. Bank of Tokyo-MitsubishitJFJ, Barclays, Citigroup, Credit Suisse, Deutsche Bank, Goldman Sachs, HSBC, JP Morgan Chase, Socidtd c€nerale and UBS whichaim to develop financial services industry standards, and related products, for Know Your Customer, Anti-Money Laundering andCounter Terrorist Financing policies.

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

theWolfsberg

The Wof Fberg Grou p Anti- Money Lau nderi n g Question nai re v,2/ 2008 / Eng I ish

6roup

Space for additional information: NlL--(Please indicate which question the information is referring to.)

Itttt!tttttttatttttttIItttat!talIrlallIIl !l IIl tlllll!a|!

Name: Mohammad Aminul IslamTitle: Vice President & Chief Anti- Money Laundering Compliance Officer

E-mail : mi 101101@primebank.com.bdSignature: @Date: 11 Julv, ?OLL

The Wolfsberg Grsup conslsts ofthe followlng leadlng Internatlonal flnancial instihrtions: Banco Santander, Bank of Tokyo-MltsublshlUFJ, Barclays, Cltlgroup, Credlt Sulsse, Deutsche Ban& Goldman Sachs, HSBC,IP Morgan Chase, Socl€t€ G€n€rale and UBS whlchalm to develop flnanclal servlces Industry standards, and related products, fior Know Your Customer, AntFMoney [aunderlng andCounter Terorlst Flnanclng pollcles,