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Afreximbank 72B El-Maahad El-Eshteraky Street Heliopolis, Cairo 11341, Egypt Roxy, Heliopolis, Cairo 11341, Egypt T +(202) 2456 4100/1/2/3/4 F +(202) 2456 4110 [email protected] afreximbank.com Questionnaire for Correspondent Banking Relationships Customer Profile 1. Name of Institution (Please attach certificate of incorporation) 2. Swift BIC 3. Website Address 4. Full address of the institution 5. Place of registration (Please attach registration certificate) 6. Legal Status (Please attached memorandum and articles of association) Limited Company Government Bank Cooperative Bank Savings Bank (under Special Law) Others 7. External Auditor (name, address, contact details, i.e. 1 Anti-Money Laundering/ Know Your Customer Compliance

Questionnaire for Correspondent Banking … · Web viewQuestionnaire for Correspondent Banking Relationships Customer Profile Name of Institution (Please attach certificate of incorporation)

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Page 1: Questionnaire for Correspondent Banking … · Web viewQuestionnaire for Correspondent Banking Relationships Customer Profile Name of Institution (Please attach certificate of incorporation)

Afreximbank72B El-Maahad El-Eshteraky StreetHeliopolis, Cairo 11341, Egypt Roxy, Heliopolis, Cairo 11341, Egypt

T +(202) 2456 4100/1/2/3/4F +(202) 2456 4110

[email protected]

Questionnaire for Correspondent Banking Relationships

Customer Profile

1. Name of Institution(Please attach certificate of incorporation)

2. Swift BIC

3. Website Address

4. Full address of the institution

5. Place of registration(Please attach registration certificate)

6. Legal Status(Please attached memorandum and articles of association)

Limited Company Government Bank

Cooperative Bank

Savings Bank (under Special Law)

Others

7. External Auditor(name, address, contact details, i.e. tel/fax/email/website)

8. Legal Advisors(name, address, contact details, i.e. tel/fax/email/website)

9. Shareholder’s equity (as of December 31, 2013)

1

Anti-Money Laundering/ Know Your Customer Compliance

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10. ListingAre your shares listed in any Stock Exchange Market(s)?

YesName of Stock Exchange Market(s):

Your stock symbol:

No

11. Primary regulatory body(ies)Please list names of the primary regulatory body(ies) that supervise(s) your institution.

12. Banking License(please attach banking license)

Yes Noa) issued by:

b) Banking license type:

c) Year of issuance:

d) Is your bank authorized to hold foreign currency accounts outside of your country?

Yes Noe) Are there any restriction on this authorization?

Yes Nof) Is your bank authorized to trade foreign exchange?

Yes Nog) Bank's tax identification number (if any):

h) Number of Domestic branches:

i) Number of Foreign branches:

N/A (We are not Bank)

13. Number of employees

14. Ratings

15. Main Business(e.g. Retail banking, Corporate banking,

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Investment banking etc.)

16. Board of Directors and Executive ManagementPlease provide a signed declaration on the Company’s letterhead confirming the Board of Directors and Executive Management team and brief profiles:

Name Nationality Title

17. Affiliates, subsidiaries

18. Financial products & servicesWhat type of financial products and services do your bank offer to your customers?

19. Customers' Major Business segmentsPlease describe your customers’ major business segments.

Do they include the following business?

(*) Casinos, Real estate agents, Dealers in precious metals and precious stones, Money Service Business, Lawyers, Notaries, Other independent legal professionals and accountants, Trust and service providers

Yes (*)(*) These segments afore mentioned occupy more than 25% shares in terms of customer portfolio of your institution.

NoPlease list your customers’ major business segments.

20. Specific laws and / or regulations covering AMLAre there any specific laws and/or regulations in place covering Anti-Money Laundering?

YesPlease list them

No

21. Enforcement actionHas your bank been fined or received any enforcement action by your regulator for a breach of Anti-Money Laundering legislation?

YesPlease attach details

No

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22. Payable-through accounts1

Does your bank allow direct use of your correspondent accounts by your customers to transact business on their behalf? I.e. Do you allow Payable-through accounts?

Yesa) Have you verified the identity of and performed on-going due diligence on your customers having direct access to your correspondent accounts?

Yes No

b) Are you able to provide relevant customer identification data upon request?

Yes No

No

1 Payable-through accounts:The above questions are based on Recommendation 7-(e) of FATF's "The Forty Recommendations". The background of the question is that "pass through account" is considered by the regulators as high risk for potential money laundering thus we need to verify that you have some kind of mechanism in place to reduce the risk of money laundering by asking you the additional questions a) & b)

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OWNERSHIP STRUCTURE/ULTIMATE BENEFICIAL OWNER

Name of Person/Company

% Shareholding Business Address(House#/Street/Town/City/Country)

If any of the owners above is a Legal Entity, please list the names of the shareholders of that Legal Entity, Shareholders, percentage of ownership (shareholding), and contact address.

The questionnaire below requires “Yes”/ “No” answers. Kindly note that an answer “yes” or “no” may also require additional information which can be supplied at the comments column.

1. General AML Policies, Practices and Procedures:

Yes / No Comments

a) Is your institution subject to laws and regulations designed to combat money laundering and Terrorist financing (AML/CFT)? Name the law(s)

Yes No

b) Is Money Laundering/Terrorist Financing Criminalized in your

Yes No

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country?

c) Does your country comply with the recommendations of FATF or any equivalent regional styled body? Please specify.

Yes No

d) Does your institution have AML compliance programme approved by your board or a senior management committee?

Yes No

e) Do you have a designated officer that is responsible for coordinating and overseeing your AML/CFT programme?

Yes No

f) Has your institution developed written policies documenting the processes that you have in place to prevent, detect and report suspicious transactions?

Yes No

g) Do you have an internal audit function that assesses your AML/CFT policies and practices on a regular basis?

Yes No

h) Do you have a designated officer that is responsible for coordinating and overseeing your AML/CFT programme?

Yes No

i) Do you have policies to reasonably ensure that you will not conduct transactions with or on behalf of shell banks through any of your accounts or products?

Yes No

j) Do you have policies covering the establishment and maintenance of relationships with Politically Exposed Persons (PEP’s), their family and close associates?

Yes No

k) Does your institution have record retention procedures that comply with applicable law? If yes, how

Yes No

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many years do you keep records?

l) Are your AML/CFT policies and practices being applied to all branches and subsidiaries?

Yes No

m) Do your policies and procedures permit you to open or maintain anonymous accounts or numbered accounts?

Yes No

n) Does your institution initiate/process transactions on behalf of non-clients (i.e. clients who conduct once –off transactions); if yes do you conduct identification and verification on these types of clients?

Yes No

o) Does your institution confirm the existence of clients via independent source documents?

Yes No

p) Has your institution been subject to any investigation, indictment, conviction, or civil enforcement related to money laundering and terrorist financing in the past five years?

Yes No

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2. Risk Assessment: Yes / No Comments

a) Does your institution have a risk-based assessment of its customer base and their transactions?

Yes No

b) Does your institution determine the appropriate level of enhanced due diligence necessary for those categories of customers and transactions that you have reason to believe pose a heightened risk of illicit activities?

Yes No

c) Does your institution perform Risk Assessments of its product, services, branches and customers? If “yes” at what interval do you undertake this project/task?

Yes No

3. Know Your Customer, Due Diligence and Enhanced Due Diligence: Yes / No Comments

a) Has your institution implemented processes for the identification your customers?

Yes No

b) Do you have a requirement to collect information regarding your customers’ business activities?

Yes No

c) Does your institution have a process to review and, where appropriate, update customer information relating to high risk client information?

Yes No

d) Do your CDD/KYC procedures require you to identify the source of your Customers’ initial funds?

Yes No

e) Does your institution have procedures to establish a record for each new customer noting their

Yes No

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respective identification documents and ‘Know Your Customer’ information?

f) Does your institution complete a risk-based assessment to understand the normal and expected transactions of its customers?

Yes No

g) Do your Customer identification and verification, and on-going due diligence procedures meet the current Recommendations of the FATF?

Yes No

h) When you are conducting wire transfers for your customers, do you require sender and beneficiary names, account numbers and reason for the transfer?

Yes No

4. Reportable Transactions and Prevention and Detection of Transactions with Illegally Obtained Funds: Yes / No Comments

a) Does your institution have policies or practices for the identification and reporting of transactions that are required to be reported to the Financial Intelligence Center?

Yes No

b) Does your institution have procedures to identify transactions structured to avoid cash transaction reporting threshold?

Yes No

c) Do you screen your customers and their transactions against any sanction list?

Yes No

d) Has your institution filed a Yes No

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suspicious transactions report with the financial intelligence center in the past two (2) years?

5. Transaction Monitoring: Yes / No Comments

a) Does your institution have a monitoring program to identify unusual and potentially suspicious transactions that cover funds transfers and monetary instruments such as managers’ cheques, payment orders, etc?

Yes No

b) Does your institution have a system (AML Software) for detecting abnormal customer transactions or patterns of activity in relation to the expected norm?

Yes No

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6. AML Training: Yes / No Comments

c) Does your institution provide AML/CFT training to relevant employees that includes:

Identification and reporting of transactions that must be reported to FIC.

Examples of different forms of money laundering involving your products and services?

Yes No

d) Do you retain records of training sessions including attendance records and relevant training materials used?

Yes No

e) Does your institution communicate new AML/CFT related laws or changes to existing AML/CFT related policies or practices to relevant employees?

Yes No

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Name of compliance officer

Designation

Full address

Email address

Phone & fax numbers

Signature & stamp & date

The undersigned, based on his/her best knowledge and belief, certifies the above referenced questions were answered considering the existing internal controls of the subject financial institutions, and further present an accurate representation of the existing state of the institution’s anti-money laundering and anti-terrorist financing internal controls and financial services activities.

COMPLETED BY

POSITION

SIGNATURE & STAMP

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Kindly attach the following additional documents when submitting this questionnaire:

Current List of Board of Directors & Senior Management, brief profiles and copies of identification.

Memorandum and Articles of Association

Certificate of Incorporation

Banking Licence

List of Authorized Signatories

Current KYC / AML Policy

Anti-bribery and Corruption Policy

Latest 2 Annual Reports

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