Questionnaire For Correspondent Banks - BLOM Bank · In relation to cross-border correspondent banking and other ... data that you have entered on this questionnaire. ... Questionnaire

Anti-Money Laundering/Combating Terrorist Financing Questionnaire For Correspondent Banks

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Full Legal Name Registered AddressHead Office Address (if different from the above)TelephoneWeb AddressDate & Place of Incorporation / EstablishmentRegistration Number/Date & Place of RegistrationOperating License Number, Type & Name of Issuer and dateName of RegulatorName and address of external auditor(s)Legal FormName of CEONumber of employeesSwift Address of InstitutionName of AML / Compliance officerName of your Financial Intelligence Unit (FIU)Legal Representative

Business ActivityPersonal / Retail BankingCommercial BankingPrivate BankingTrade FinanceTrust / Asset ManagementInsuranceOther (please specify)Purpose / Background of the business relationship with Blom Bank SALIs your bank part of a Group. If yes, which group?

Country Type No. of locations

Institution publicly held or privately ownedStock exchange name/SymbolAmount of share capital

Name of Shareholder Ownership interest (%) Country / PEP* (yes/no)

Name Position Years of service / PEP* (yes/no)

Name Designation PEP* (yes/no)Names of members of the board (attach additional sheets, if necessary)

Section 2 - Business ActivitiesList of Affiliates, branches, Agencies or subsidiaries, if any (attach additional sheets, if necessary)

Section 3 - Ownership Information

*PEP - Politically exposed persons are individuals who are or have been entrusted with prominent public functions, for example Head of State or of government, senior politicians, senior government, judicial or military officials, senior executives of state owned corporations, important politically party officials, or their family members or close associates.

Section 1 - General Information

List of names of principal shareholders (attach additional sheets, if necessary)

Section 4 - Management InformationNames of principal officers and directors of institution (attach additional sheets, if necessary)

Principal line of business activityPlease indicate the percentage of appropriate business activity your institution is involved

Percentage (%)


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Yes No N/A

4. Does the FI have a policy prohibiting accounts/relationships with shell banks? (A shell bank is defined as a bank incorporated in a jurisdiction in which it has no physical presence and which is unaffiliated with a regulated financial group.)

3. Does the FI client have an internal audit function or other independent third party that assesses AML/CFT policies and practices on a regular basis?

Are there any current material audit findings relating to AML?

What is the frequency of the independent review?

Is screening conducted at client onboarding to identify PEPs and related individuals? Is there automated, ongoing screening of customers and connected parties?Please provide details:

What enhanced due diligence/monitoring is conducted for PEPs?

7. Does the FI have record retention procedures that comply with applicable law?

For how many years?

5. Does the FI have policies to reasonably ensure that they will not conduct transactions with or on behalf of shell banks through any of its accounts or products?

6. Does the FI have policies covering relationships with Politically Exposed Persons (PEP's), their family and close associates?

What is the frequency of their review?

Section 5 - Regulatory Environment

1. Has your country established laws designed to prevent money laundering and terrorist financing and is your institution subject to such laws?

Questions

If yes, please list the name(s) of your country's relevant law(s) & circular(s)/governing body below:

2. Is the AML/CFT compliance program approved by the FI's board or a senior committee?

Section 6 - General AML policies, practices and procedures

If so, please describe.

When did the most recent AML regulatory examination take place? Describe any material findings.

Describe the structure of the AML function, including the approximate number of dedicated resources.Please provide details:

Does your bank review those policies and procedures?If Yes, how often are reviewed?


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Travel Agencies

Government Agencies

Government Constructors

Embassies and/or Consulates

Professional Services Providers (PSP) where a beneficial owner is unknown

12. Does your FI provide a substantial portion of their financial products or services to any of the below market segments :

13. Does the FI determine the appropriate level of enhanced due diligence necessary for those categories of customers and transactions that the FI has reason to believe pose a heightened risk of illicit activities at or through the FI?

Please describe the Enhanced Due Diligence.

Section 8 - Know Your Customer, Due Diligence and Enhanced Due Diligence

14. Has the FI implemented processes for the identification of those customers on whose behalf it maintains or operates accounts or conducts transactions?

8. Are the FI's AML policies and practices being applied to all branches and subsidiaries of the FI both in the home country and in locations outside of that jurisdiction?

How do you communicate and enforce the policy and practices across your network of domestic and foreign offices?Please provide details:

Exchange Dealers

Casinos

15. Does the FI have a requirement to collect information regarding its customer's business activities?

Please describe your procedures for updating and reviewing customer information.

Section 7 - Risk Assessment

11. Does the FI have a risk-based assessment of its customer base and their transactions?

How are clients identified/classified by risk levels?

Is a consistent KYC approach employed throughout the group?

Is KYC due diligence conducted for all clients?

Precious Gem Dealers

Commodity Trades/Providers

Please describe the customer risk assessment methodology:

Please describe the process used to verify the identity of the customers.

9. Does the FI have policies to reasonably ensure that it only operates with correspondent banks that possess licenses to operate in their countries of origin?

10. Does the FI assess its FI customers' AML policies or practices associated with its correspondent bank customers on the basis of the countries and types of banks served?

What is the frequency of periodic review for clients at different risk levels? (High, Medium, Low)


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Does the bank review source of funds when conducting due diligence on new customers?

21. Has the FI developed a written policies documenting the processes that they have in place to prevent, detect and report suspicious transactions?

Please provide details:

What is the minimum documentation standard for new customers?

Describe your monitoring process that you perform in order to detect suspicious activity.

16. Does the FI complete a risk-based of its onboarding customer's assessment to understand the normal and expected transactions of its customers?

Section 9 - Transaction Monitoring

19. Does the FI have a monitoring program for unusual and potentially suspicious activity that covers funds transfers and monetary instruments such as traveler's checks, money orders, etc?

Is transaction monitoring automated? What system is used?Please provide details:

What are the local thresholds for cash reporting?Please provide details:

18. Does the FI screen customers and transactions against lists of persons, entities or countries issued by government/competent authorities?

What lists are customers screened against at onboarding?Please provide details:

What lists are transactions screened against?Please provide details:

Is ongoing/transaction screening automated? What system is used?Please provide details:

20. Where cash transaction reporting is mandatory, does the FI have procedures to identify transactions structured to avoid such obligations?

What lists are existing customers screened against? Please provide details (frequency) :

Are cash transactions covered by automated transaction monitoring? If not, how are they monitored?Please provide details & specify if there is an aggregate cash transactions monitoring:

Who reviews alerts generated (RMs, Compliance etc.)? How many staff undertakes these reviews?Please provide details:

Does the bank have a formal exit process to deal with those customers it deems to no longer be acceptable?Please provide details:

17. Does the FI have procedures to establish a record for each new customer noting their respective identification documents and "Know Your Customer" information?

Section 10 - Reportable Transactions, Prevention and Detection of Transactions with Illegally Obtained Funds


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30. Does the FI have a specific regulation to control the risks associated with the non-face-to face business (phone banking, banking on-line…etc.) and relationships through intermediaries or third parties?

What is the frequency of training delivered for each employee category?Please provide details:

24. Does the FI retain records of its training sessions including attendance records and relevant training materials used?

25. Does the FI communicate new AML related laws or changes to existing AML related policies or practices to relevant employees?

Briefly describe your policies and procedures for identifying suspicious activity and the process for escalating identified suspicious activity to local law enforcement authority.

If the answer is affirmative, provide details of Due Diligence requirements that your bank has implemented with respect to customers who have direct access to the accounts of the Bank correspondent.

32. Does your institution take reasonable steps to obtain information relevant to assess & mitigate money laundering risks associated with your bank's correspondent accounts for other foreign banks (i.e. nested correspondent activity)?

33. Does the FI adhere to the Wolfsburg Transparency Principles and the appropriate usage of the Swift MT 202/202COV and MT 205/205COV message formats?

Please provide details:

Section 11 - AML Training

23. Does the FI provide AML training to relevant employees that include:- Identification and reporting of transactions they must be reported to government authorities.- Examples of different forms of money laundering involving the FI's products and services.- Internal policies to prevent money laundering.

31. Does the FI offer "Payable Through Account" (Clear-Through)?(These are accounts of the correspondent Bank that are used directly by third parties to conduct commercial operations or any other form of self-employed.)

Section 12 - Key Regulatory Issues

26. Does the FI offer anonymous accounts or numbered accounts, for which your bank does not have full particulars of the beneficial owner?

27. Does the FI send transfers or bank transactions on behalf of non-customers, without obtaining proof of identification?

28. Does the FI require full information on the issue of transfers, including the name of the originator and beneficiary, your address and account number?

29. In relation to cross-border correspondent banking and other similar relationships, does the FI gather sufficient information about a respondent institution to understand their business, reputation, quality of supervision and regulatory history?

If yes, please provide details:

22. Does the FI have policies or practices for the identification and reporting of transactions that are required to be reported to the authorities?


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Please inform us in writing as soon as possible of any changes to the data that you have entered on this questionnaire.

BLOM BANK SAL - GROUP COMPLIANCE DIVISION [email protected]

Verdun - Rachid Karami St., BLOM BANK Building P.O.Box: 11-1912 Riad El Solh, Beirut 1107 2807, Lebanon Phone: (961-1)729945 Fax: (961-1)729955

If yes, please specify.Date of issuance / License of body country.

37. Does your institution have a branch or subsidiary operating under offshore banking license?

If yes, please specify.

38. Is your institution a government - owned institution?

If yes, please specify.

35. Has your institution been involved in any proceedings of public relevance or sanctioned in relation with money laundering or terrorist financing in the last five year?

If so, give details of the reason and the outcome.

Section 13 - General

34. Does the FI employ third parties to carry out some of the functions of the FI?

If yes to question 29 does the FI provide AML/CFT training to the 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 Customer's products and services.- Internal policies to prevent money laundering.

36. Is your institution operating under offshore banking license?


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I confirm that I am authorised to complete this document:

Name:

Position:

Date:

Signature:

Institution Stamp:

Thank you for your co-operation


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Please provide details: (and if not, provide the expected date of Syrian EDD implement)

CommentsIf you wish to state any relevant fact or clarify any matter regarding any of your answers to this questionnaire, please do so here.

B - If yes to part A , does your institution apply enhanced due diligence measures to transactions emanating from or destined to Syria (Syria EDD)?

* For the purposes of this questionnaire, an Iranian financial institution means a body corporate, trust, partnership, fund, unincorporated association or organization, established under the laws of Iran that engages, directly or indirectly, in the business of providing financial services.(e.g. any transactions, investments, activities or planned activities with (or in) any person or entity located in Iran or with (or in) any entity owned or controlled by any entity located in Iran or reside in or have officies.)

B - If yes to part A, does your institution apply enhanced due diligence measures to transactions emanating from or destined to Iran (Iran EDD)?

Please provide details: (and if not, provide the expected date of Iran EDD implement)


SYRIA SANCTIONS STATEMENT / QUESTIONNAIREA - Does your institution provide or maintain correspondent banking products/services to, with or for the benefit of, or on the direction or order of, a Syrian financial institution* or a subsidiary of a Syrian financial institution?If yes, please list the name of each Syrian financial institution or subsidiary thereof. (Financial institution or subsidiary).

* For the purposes of this questionnaire, a Syrian financial institution means a body corporate, trust, partnership, fund, unincorporated association or organization, established under the laws of Syria that engages, directly or indirectly, in the business of providing financial services.(e.g. any transactions, investments, activities or planned activities with (or in) any person or entity located in Iran or with (or in) any entity owned or controlled by any entity located in Syria or reside in or have officies.)

If yes, please list the name of each Iranian financial institution or subsidiary thereof. (Financial institution or subsidiary).

Major Sanctioned Countries QuestionnaireBLOM BANK's policy is to fully comply with UN, EU, US and relevant local sanctions. In this regard, BLOM BANK endeavors, among other things, to understand the extent of its clients' activities with certain sensitive or major sanctioned countries.

Please provide the following information about your company, the company's group and its affiliates. Additional information may be requested upon review.

Section 14 - SanctionsIRAN SANCTIONS STATEMENT / QUESTIONNAIRE

A - Does your institution provide or maintain correspondent banking products/services to, with or for the benefit of, or on the direction or order of, an Iranian financial institution* or a subsidiary of an Iranian financial institution?


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If you wish to state any relevant fact or clarify any matter regarding any of your answers to this questionnaire, please do so here.

SUDAN SANCTIONS STATEMENT / QUESTIONNAIRE

A - Does your institution provide or maintain correspondent banking products/services to, with or for the benefit of, or on the direction or order of, a Sudanese financial institution* or a subsidiary of a Sudenese financial institution?

If yes, please list the name of each Sudanese financial institution or subsidiary thereof. (Financial institution or subsidiary).

* For the purposes of this questionnaire, a Sudanese financial institution means a body corporate, trust, partnership, fund, unincorporated association or organization, established under the laws of Sudan that engages, directly or indirectly, in the business of providing financial services.(e.g. any transactions, investments, activities or planned activities with (or in) any person or entity located in Iran or with (or in) any entity owned or controlled by any entity located in Sudan or reside in or have officies.)

B - If yes to part A , does your institution apply enhanced due diligence measures to transactions emanating from or destined to Sudan (Sudan EDD)?

Please provide details: (and if not, provide the expected date of Sudan EDD implement)


Comments

CUBA SANCTIONS STATEMENT / QUESTIONNAIREA - Does your institution provide or maintain correspondent banking products/services to, with or for the benefit of, or on the direction or order of, a Cuban financial institution* or a subsidiary of an Cuban financial institution?

If yes, please list the name of each Cuban financial institution or subsidiary thereof. (Financial institution or subsidiary).

* For the purposes of this questionnaire, a Cuban financial institution means a body corporate, trust, partnership, fund, unincorporated association or organization, established under the laws of Cuba that engages, directly or indirectly, in the business of providing financial services.(e.g. any transactions, investments, activities or planned activities with (or in) any person or entity located in Iran or with (or in) any entity owned or controlled by any entity located in Cuba or reside in or have officies.)

B - If yes to part A , does your institution apply enhanced due diligence measures to transactions emanating from or destined to Cuba (Cuba EDD)?

Please provide details: (and if not, provide the expected date of Cuba EDD implement)


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A - Does your institution provide or maintain correspondent banking products/services to, with or for the benefit of, or on the direction or order of, a North Korean financial institution* or a subsidiary of a North Korean financial institution?If yes, please list the name of each North Korean financial institution or subsidiary thereof. (Financial institution or subsidiary).

* For the purposes of this questionnaire, a North Korean financial institution means a body corporate, trust, partnership, fund, unincorporated association or organization, established under the laws of North Korea that engages, directly or indirectly, in the business of providing financial services.(e.g. any transactions, investments, activities or planned activities with (or in) any person or entity located in Iran or with (or in) any entity owned or controlled by any entity located in North Korea or reside in or have officies.)

B - If yes to part A , does your institution apply enhanced due diligence measures to transactions emanating from or destined to North Korea (North Korea EDD)?

Please provide details: (and if not, provide the expected date of North Korea EDD implement)


MYANMAR/BURNA SANCTIONS STATEMENT / QUESTIONNAIRE

If you wish to state any relevant fact or clarify any matter regarding any of your answers to this questionnaire, please do so here.

A - Does your institution provide or maintain correspondent banking products/services to, with or for the benefit of, or on the direction or order of, a Myanmar/Burnese financial institution* or a subsidiary of a Myanmar/Burnese financial institution?

If yes, please list the name of each Myanmar/Burnese financial institution or subsidiary thereof. (Financial institution or subsidiary).

* For the purposes of this questionnaire, a Myanmar/Burnese financial institution means a body corporate, trust, partnership, fund, unincorporated association or organization, established under the laws of Myanmar/Burna that engages, directly or indirectly, in the business of providing financial services.(e.g. any transactions, investments, activities or planned activities with (or in) any person or entity located in Iran or with (or in) any entity owned or controlled by any entity located in Myanmar/Burna or reside in or have officies.)

B - If yes to part A , does your institution apply enhanced due diligence measures to transactions emanating from or destined to Myanmar/Burna (Myanmar/Burna EDD)?

Please provide details: (and if not, provide the expected date of Myanmar/Burna EDD implement)

Comments

NORTH KOREA SANCTIONS STATEMENT / QUESTIONNAIRE


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Company Name: Date:

Company Address: Completed by: (Name & Title)

Company Group Name:(If applicable)

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Questionnaire For Correspondent Banks - BLOM Bank · In relation to cross-border correspondent banking and other ... data that you have entered on this questionnaire. ... Questionnaire