the Wolfsberg Group - Andbank...©The Wolfsberg Group 2018 Page 1 CBDDQ V1.2 Wolfsborg Group Correspondent Banking Due Diligence Questionnaire (CBDDQ) V1.2 11 Provide the full legal

Wolfsberg Group Correspondent Ban ing Due Diligence Questionnaire (CBDDQ) V1.2

theWolfsberg

Group

Financial Instiiution Ñame:

Location (Country):

ANDORRA BANC AGRICOL REIG, SA

C/Manuel Cerqueda i Escalar, 4-6, AD700 Escaldes-Engordany, Andorra

he questionnaire is required to be answered on a Legal Entity (LE) Level. Ibis means the Financial Instltution will answerthe questionnaire at anultímate parent / head office & subsidiary level for which any branches would be considered covered by that parent/subsidiary DDQ. Ibis questionnaireshould not cover more than one LE. Each question in the DDQ will need to be addressed from the perspective of the LE and on behalf of all of itsbranches. If a response for the LE differed for one of Its branches this needs to be highlighted and detall regarding this difference captured at the end ofeach subsection. If a branch business activity (producís offered, Client base etc.) is significantly different than its head office, the branch should completea sepárate questionnaire.

>Jo # | Question | Answer

1. ENTITY &OWNERSHIP1 ull Legal Ñame ANDORRA BANC AGRICOL REIG, SA

2 4ppend a list of branches which are covered byhis questionnaire

Please visit our website: https://www.andbank.com/en/about-us/andbank-group/

3 Full Legal (Registered) Ad ress C/Manuel Cerqueda i Escaler, 6, AD700 Escaldes-Engordany, Andorra

4 Full Primary Business A dress (if different fro above)

5 Date of Entity incorporation/ establishment 30/12/1930

6 Select type of ownership and append anownership chart if available

Privately owned company.

6 a Publicly Traded (25% of shares publicly traded) No

6 a1 f Y, indícate the exchange traded on and tickerSymbol

,6b Vlember Owned/ Mutual No6c Sovernment or State Owned by 25% or more ío

, 6 d rivately Owned es6 d1 f Y, provide details of shareholders or ultímate

leneficial owners with a holding of 10% or moreMr. Oscar RIBAS REIG: 28.57%

7 Ya of the Entity's total shares composed of bearer¡bares

No

8 3oes the Entity, or any of its branches, opérateinder an Offshore Banking License (OBL) ? No

8 a f Y, provide the ña e of the rele an branch/esvhich opérate under an OBL

9 4ame of primary financial regulator / supervisoryauthority

Autoritat Financera Andorrana

10 Dro ide Legal Entity Identifier (LEI) if available 549300UHUTTOEC14D714

©The Wolfsberg Group 2018 Page 1 CBDDQ V1.2

Wolfsborg Group Correspondent Banking Due Diligence Questionnaire (CBDDQ) V1.2

11 Provide the full legal ñame of (he ultímate paren(if dlfferent from the Entity completing the DDQ)

12 Jurisdiction of licensing authority and regulatorof ultímate parent

13 Select the buslness areas applicable to theEntity

13 a Retail Banking Yes13 b Prívate Banking / Wealth Management Yes13 c Commercial Banking Yes13 d Transactional Banking No13 e Investment Banking No13 f Financial Markets Trading Yes13 g Securities Services/ Custody Yes13 h Broker/Dealer Yes13 i Multilateral Development Bank No13J Other

14 Does the Entity have a significant (10% ormore) offshore customer base, either bynumber of customers or by re enues (where off¬shore means not domiciled in the jurisdictionwhere bank Services are beina orovided) ?

No

14 a If Y, provide details of the country and %

15 Select the closest valué:15a Number of employees 201-50015 b Total Assets Between $10 and $100 million16 Confirm that all responses provided in the

above Section ENTITY & OWNERSHIP arerepresentative of all the LE's branches

Yes

16 a If N, clarify which questions the difference/srelate to and the branch/es that this applies to.

16 b If appropriate, provide any additionalinformation / context to the answers in thissection.

©The Wolfsberg Group 2018 Page2 CBDDQ V1.2

Wolfsberg Group Correspondent Banking Due Diligence Questionnaire (CBDDQ) 1.2

2. PRODUCTS & SERVICES17 Does the Entity offer the following producís and

Services:17 a Correspondent Banking No17 a1 If Y17 a2 Does the Entity offer Correspondent Banking

Services to domestic banks?17 a3 Does the Entity allow domestic bank clients to

provide downstream relationships?17 a4 Does the Entity have processes and procedures

in place to ¡dentify downstream relationships

17 a5 Does the Entity offer correspondent bankingServices to Foreiqn Banks?

17 a6 Does the Entity allow downstream relationshipswith Foreian Banks?

17 a7 Does the Entity have processes and proceduresin place to identify downstream relationshipswith Foreign Banks?

17 a8 Does the Entity offer correspondent bankingServices to requlated MSBs/MVTS?

17 a9 Does the Entity allow downstream relationshipswith MSBs/MVTS?

17 a10 Does the Entity have processes and proceduresin place to identify downstream relationshipswith MSB /MVTS?

17 b Prívate Banking (domestic & intemational) Yes17 c Trade Finance No17 d Payable Throuqh Accounts No

17 e Stored Valué Instruments No17 f Cross Border Bulk Cash Delivery No17 g Domestic Bulk Cash Delivery No

17 h Inte ational Cash Letter No171 Remóte Deposit Capture No

17 i Virtual /Digital Currencies No17 k Low Price Securities No17 I Hold Mail No

17 m Cross Border Remittances No17 n Service to walk-in customers (non-account

holders)No

17 o Sponsorinq Prívate ATMs No17 p Other high risk producís and Services identified

by the Entity

18 Confirm that all responsos provided in theabove Section PRODUCTS & SERVICES are Yes

18a If N, clarify which questions the difference/srelate to and the branch/es that this applies to.

18b If appropriate, provide any additionalinformation / context to the answers in thissection.

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Wolfsberg Group Corresponden Banking Due Diligence Questionnaire (CBDDQ) V1.2

3. AML, CTF & SANCTIONS PROGRAMME19 Does Ihe Entity have a programme that sets

minimum AML, CTF and Sanctions standardsreqardinq the followinq comoonents:

19 a Appointed Officer wilh sufficientexperience/e pertise Yes

19 b Cash Reportinq Yes19 c CDD Yes19 d EDD Yes19 e Beneficia! Ownership Yes19 f Independen Testing Yes19 q Periodic Review Yes19 h Policies and Procedures Yes19 I Risk Assessment Yes19J_Sanctions Yes19 k PEP Screening Yes19 1 Adverse Information Screening Yes19 m Suspicious Activity Reportinq Yes19 n Training and Education Yes19 o Transaction Monitoring Yes20 How many full time employees are in the

Entit s A , CTF & Sanctions ComplianceDepartment?

Less than 10

21 Is the Entity s AML, CTF & Sanctions policyapproved at least annually by the Board orequi alen Sénior Management Committee?

Yes

22 Does the Board or equivalent SéniorManagement Committee receive regularreporting on the status of the AML, CTF &Sanctions orooramme?

Yes

23 Does the Entity use third parties to carry out anycomponents of its AML, CTF & Sanctionsprogramme?

No

23 a If Y, provide further details

24 Conf rm that all responses provided in the aboveSection AML, CTF & SANCTIONS Programmeare Representative of all the LE's branches

Yes


24 b f appropriate, provide any additionalnfor ation / context to the answers in thissection.


Wolfsberg Group Correspondent Banking Due Diligence Questionnaire (CBDDQ) VI.2

4. ANTI BRIBERY & CORRUPTION25 as the Entity documented policies and

arocedures consistent with applicable ABCregulations and requirements to [reasonably]prevent, detect and report bribery andcorruption?

Yes

26 Does the Entity have an enterprise wideprogramme that sets minimum ABC standards? Yes

27 Has the Entity appointed a designated officer orofficers with sufficient experience/expertiseresponsible for coordinating the ABCprogramme?

Yes

28 Does the Entity have adequate staff ithappropriate levels of experience/expertise toimplement the ABC programme?

Yes

29 Is the Entity's ABC programme applicable to:

29 a Joint venturos Yes

29 b Third parties acting on behalf of the Entity Yes

30 Does the Entity have a global ABC policy that:

30 a Prohibits the giving and receiving of bribes?This ¡ncludes promising, offering, giving,solicitation or receiving of anything of valué,directly or indirectly, if improperly intended toinfluence action or obtain an advantage

Yes

30 b Ineludes enhanced requirements regardinginteraction with public officials? Yes

30 c Ineludes a prohibition against the falsification ofbooks and records (this may be within the ABCpolicy or any other policy applicable to the LegalEntity)?

Yes

31 Does the Entity have Controls in place tomonitor the effectiveness of their ABCprogramme?

Yes

32 Does the Entity's Board or Sénior ManagementCommittee rece ive regular anagementInformation on ABC matters?

Yes

33 Does the Entity perform an Enterprise WideABC risk assessment? No

33 a If Y select the frequeney

34 Does the Entity have an ABC residual risk ratingthat is the net result of the Controlseffectiveness and the inherent riskassessment?

No

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Wolfsberg Group Correspondent Banking Due Diligence Questionnaire (CBDDQ) V1.2

35 Does Ihe Entity s ABC EWRA cover Ihe inherent¡sk componenls delaüed below:

35 a tential liability created by intermediaries andDther third-party pro iders as appropriate No

35 b Dorruplion risks associated with the countriesand induslries in which Ihe Entity does business,irectly or throuqh intermediaries

o

35 c Fransaclions, producís or Services, includingIhoselhal involve state-owned or state-controlledenlilies or public officials

No

35 d on iplion risks associated with gifts andlospilalily, hiring/internships, charitablelonalions and polilical conlribulions

No

35 e anges in business aclivilies Ihal mayTiaterially increase Ihe Entily's corruplion risk No

36 Does the Entily's intemal audit function or otherindependen third party co er ABC Policies andProcedures?

No

37 Does the Entity provide mandatory ABC trainingo:

37 a 3oard and Sénior Committee Management No37 b 1 st Line of Defence No37 c 2nd Line of Defence No37 d 3rd Line of Defence No37 e 3rd parties to which specific compliance activities

subject to ABC risk have been outsourcedNo

37 f "'Jon-employed workers as appropriatecontractors/consultants)

o

8 oes Ihe Entity provide ABC training that isargeted to specific roles, responsibililies andactivities? No

39 Donfirm that all responses provided in the aboveSection Anti Bribery & Corruplion areepresentative of all the LE's branches Yes

39 a f N, clarify which questions the difíerence/selate to and the branch/es that this applies to.

39 b appropriate, provide any additional informalioncontext to the answers in this section.

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Wolfsberg Group Correspondent Banking Due Dili ence Questlonnaire (CBDDQ) V1.2

5. POLICIES & PROCEDURES40 Has the Entity documented policies and

jrocedures consisten with appiica le AML,GIF & Sanctions regulations and requirementso reasonablv orevent. detect and reoort:

40 a i/ioney launderinq Yes40 b Terrorist financinq Yes40 c Sanctions violations Yes41 Are the Entit/s policies and procedures Yes

42 Are the Entit s policies and procedures gapped

42 a US Standards No42 a1 f Y, does the Entity retain a record of the

42 b EU Standards No42 b1 If Y, does the Entity retain a record of the

results?43 Does the Entity have policies and procedures

that:

43 a Prohibit the opening and keeping of anonymousand fictitious named accounts Yes

43 b Prohibit the opening and keeping of accountsfor unlicensed banks and/or NBFls Yes

43 c Prohibit dealing with other entities that providebanking Services to unlicensed banks Yes

43 d Prohibit accounts/relationships with shell banksYes

43 e Prohibit dealing with another entity that providesServices to shell banks Yes

43 f Prohibit opening and keeping of accounts forSection 311 designated entities Yes

43 g Prohibit opening and keeping of accounts forany of unlicensed/unregulated remittanceagents, exchanges houses, casa de cambio,bureaux de change or money transfer agents

Yes

43 h Assess the risks of relationships with PEPs,including their family and cióse associates Yes

43 i Define escalation processes for financial crimerisk issues Yes

43 j Define the process, where appropriate, forterminating existing customer relationships dueto financial crime risk

Yes

43 k Specify how potentially suspicious adivityidentified by employees is to be escalated andinvestigated

Yes

43 I Outline the processes regarding screening forsanctions, PEPs and negativo media Yes

43 m Outline the processes for the maintenance ofinternal "watchlists" Yes

44 Has the Entity defined a risk tolerancestatement or similar document which defines arisk boundary around their business?

Yes

45 Does the Entity have a record retentionprocedures that comply with appiicable laws? Yes

45 a If Y, what is the retention period? 5 Years or more

46 Confirm that all responsos provided in theabove Section POLICES & PROCEDURES arerepresentativo of all the LE's branches

Yes


46 b If appropriate, provide any additionalInformation / context to the answers in thissection.


Wolfsberg Group Correspondent Banking Due Diligence Queslionnaire (CBDDQ) V1.2

6. AML, CTF & SANCTIONS RISK ASSESSMENT47 Dees the Entity's AML & CTF EWRA co er the

inherent risk components detailed below:

47 a Client Yes

47 b Product Yes

47 c Channel Yes

47 d Geography Yes

48 Does the Entity's AML & CTF EWRA co er theControls effectiveness components detailedbelow:

48 a Transaction Monitoring Yes

48 b Customer Due Diligence Yes

48 c PER Identification Yes

48 d Transaction Screeninq Yes48 e Ñame Screening against Adverse edia &

Negative News Yes

48 f Training and Education Yes

48 g Governance Yes

48 h Management Information Yes

49 Has the Entity's AML & CTF EWRA beencompleted in the last 12 months? Yes

49 a If N, provide the date when the last AML & CTFEWRA was completed.

50 Does the Entity's Sanctions EWRA cover theinherent risk components detailed below:

50 a Client Yes

50 b Pro uct Yes

50 C Channel Yes

50 d Geography Yes

51 Does the Entity's Sanctions EWRA cover theControls effectiveness components detailedbelow:

51 a Customer Due Diligence Yes51 b Transaction Screening Yes

51 c Ñame Screening Yes51 d List Management Yes

51 e Training and Education Yes

51 f Governance Yes

51 g Management Information Yes

52 Has the Entity's Sanctions EWRA beencompleted in the last 12 months? Yes

52 a If N, provide the date when the last SanctionsEWRA was completed.

53 Confirm that all responsos provided in theabove Section AML, CTF & SANCTIONS RISKASSESSMENT are representative of all theLE s branches

Yes

53 a f N, clarify which questions thedifference/srelate to and the branch/es that thisapplies to.

53 b f appropriate, provide any additionalnformation / context to the answers in thissection.

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Woifsberg Grou Correspondent Banking Due Diligence Questionnaire (CBDDQ) VI.2

7. KYC, CDD and EDD54 Does the Entity verify the identity of the

customer? Yes

55 Do the £0(11 5 poiicies and procedures set outwhen CDD must be completed, e.g. at the timeof onboarding or within 30 days

Yes

56 Which of the following does the Entity gatherand retain when conducting CDD? Selectall that apply:

56 a Ownership structure Yes

56 b Customer identification Yes

56 c Expected activity Yes

56 d Nature of business/employment Yes

56 e Product usage Yes56 f Purpose and nature of relationship Yes

56 g Source of funds Yes

56 h Source of wealth Yes

57 Are each of the following identified:

57 a Ultimate beneficia! ownership Yes

57 a1 Are ultimate beneficial owners verified? Yes

57 b Authorised signatories (where applicable) Yes

57 c Key controilers Yes57 d Other relevant parties yes like representants

58 What is the Entit s mínimum (lowest) thresholdapplied to beneficial ownership identification ? 10%

59 Does the due diligence process result incustomers receiving a risk classification? Yes

60 If Y, what factors/criteria are used to determinethe customer s risk classification? Select all thatapply:

60 a Product Usage Yes

60 b Geography Yes

60 c Business Type/lndustry Yes

60 d Legal Entity type Yes60 e Adverse Information Yes

60 f Other (specif ) PEP,

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Wolfsberg Group Corres ondent Banking Due Dlligence Questionnaire (CBDDQ) V1.2

61 Dees (he Entity have a risk ased approach toscreening customers for adversemedia/negative news?

Yes

62 If Y, is this at:

62 a Onboarding Yes62 b KYC renewal Yes62 c Trigger event Yes63 What ¡s the method used by Ihe Entily to screen

for adverse media / negative news?

63 a Automated

63 b Manual

63 c Combination of automated and manual Yes

64 Does the Entity have a risk based approach toscreening customers and connected parties todeter ine whether they are PEPs, or controlledby PEPs?

Yes

65 If Y, is this at:

65 a Onboarding Yes65 b KYC renewal Yes65 c Trigger event Yes66 What is the method used by the Entity to screen

PEPs?66 a Automated

66 b Manual

66 c Combination of automated and manual Yes67 Does the Entity have policies, procedures and

processes to review and escálate potentialmatches from screening customers andconnected parties to determine whether theyare PEPs, or controlled by PEPs?

Yes

68 Does the Entity have a process to review andupdate customer information based on:

68 a KYC renewalYes

68 b Trigger event Yes

69 Does the Entity maintain and report metrics oncurren and past periodic or trigger event duediligence reviews? Yes

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70 From the list below, which categories ofcustomers or industries are subject to EDD and/or are restricted, or prohibited by the Entit sFCC programme?

70 a Non-account customers Prohibited70 b Offshore customers EDD & Restricted on a risk based approach

70 c Shell banks Prohibited70 d MVTS/ MSB customers EDD & Restricted on a risk based approach

70 e PEPs EDD & Restricted on a risk based approach

70 f PEP Related EDD & Restricted on a risk based approach

70 g PEP Glose Associate EDD & Restricted on a risk based approach

70 h Correspondent Banks EDD on a risk based approach

70 h1 If EDD or EDD & Restricted, does the EDDassessment contain the elements as set out inthe Wolfsberg Correspondent BankingPrincipies 2014?

Yes

70 i Arms, defense, military Prohibited

70 j Atomic power Prohibited70 k Extractive industries None of the above

70 I Precious metáis and stones EDD on a risk based approach

70 m Unregulated charities Prohibited70 n Regulated charities EDD on a risk based approach

70 o Red light business / Adult entertainment Prohibited

70 p Non-Government Organisations EDD on a risk based approach

70 q Virtual currencies Prohibited70 r Marijuana Prohibited70 s Embassies/Consulates Prohibited70 t Gambling Prohibited

70 u Payment Service Provider EDD & Restricted on a risk based approach

70 v Other (specify)

71 If restricted, provide details of therestriction

Depending on several elements such us geographical situation, declared activity, negativa news,etc.... All of them require the Compliance committee approval.

72 Does the Entity perform an additional control orquality review on clients subject to EDD? Yes

73 Confirm that all responsos provided in theabove Section KYC, CDD and EDD arerepresentative of all the LE's branches

Yes

73 a If N, clarify which questions the difference/srelate to and the branch/es that this applies to

73 If appropriate, provide any additionalinformation / context to the answers in thissection.



8. MONITORING & REPORTING74 oes the Entity have risk based policies,

procedures and monitoring processes for theIdentification and reporting of suspiciousactivity?

Yes

75 What is the method used by the Entity tomonitor transactions for suspicious activities?

75 a Automated No75 b Manual No75 c Combination of automated and manual Yes

76 If manual or combination selected, specify whattype of transactions are monitored manually Specific cash Controls, Paypal, Virtual terminal point of sale Controls, credit cards use in high risk

countries

77 Does the Entity have regulatory requirements toreport currency transactions? Yes

77 a If Y, does the Entity have policies. proceduresandprocesses to comply ith currencyreporting requirements?

Yes

78 Does the Entity have policies. procedures andprocesses to review and escálate mattersarising from the monitoring of customertransactions and activity?

Yes

79 Confirm that all responsos provided in theabove Section MONITORING & REPORTINGare representative of all the LE's branches Yes

79 a If N. clarify which questions the difference/srelate to and the branch/es that this applies to


9. PAYMENT TRANSPARENCY80 Does the Entity adhere to the Wolfsberg Group

Payment Transparency Standards? Yes

81 Does the Entity have policies, procedures andprocesses to [reasonably] comply with and haveControls in place to ensure compliance with:

81 a FATF Recommendation 16 Yes

81 b Local Regulations Yes

81 bl Specify the regulation Law 14/2017 on prevention and fight against the laundering of money or securities and the financingof terrorismlaw 8/2018 on payment Services and electronic moneyLaw 8/2018 on payment Services and electronic money

81 c If N, explain

82 Does the Entity have processes in place torespond to Request For Infor ation (RFIs) fromother entibes in a timely manner? Yes

83 Does the Entity have Controls to support thenclusion of required and accurate originatorinformation in intemational payment messages? Yes

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84 Dees the Entity have Controls to support thenelusion of required beneficiary in InternationalDayment messages? Yes

85 Confirm that all responsos provided in theaboveSection PAYMENT TRANSPARENCYare representativa of all the LE's branches Yes


85 b If a propriate, provide any additionalinformation / context to the answers in thissection.

10. SANCTIONS86 oes the Entity have a Sanctions Policy

approved by management regardingcompliance with sanctions law applicable to theEntity, including ith respect its businessconducted with, orthrough accounts held atforeign financial institutions?

Yes

87 Does the Entity have policies, procedures, orother Controls reasonably designed to preventthe use of another entit s accounts or Servicesin a manner causing the other entity to viólatesanctions prohibitions applicable to the otherentity (including prohibitions within the otherentit/s local jurisdiction)?

Yes

88 Does the Entity have policies, procedures orother Controls reasonably designed to prohibitand/or detect actions taken to evade applicablesanctions prohibitions, such as stripping, or theresubmission and/or masking, of sanctionsrelevan information in cross bordertransactions?

Yes

89 Does the Entity screen its customers, includingbeneficial ownership information collected bythe Entity, during onboarding and regularlythereafter against Sanctions Lists?

Yes

90 What is the method used by the Entity?90 a Manual o

90 b Automated Yes

90 c Combination of Automated and anual No

91 Does the Entity screen all sanctions relevan data, including at a mínimum, entity andlocation information, contained in cross bordertransactions against Sanctions Lists?

Yes

92 What is the method used by the Entity?92 a Manual No92 b Automated Yes92 c Combination Automated and Manual No93 Select the Sanctions Lists used by the

Entity in its sanctions screening processes:

93 a Consolidated United Nations Security CouncilSanctions List (UN) Used for screening customers and beneficial owners and for filtering transactional data

93 b United States Department of the Treasur sOffice of Foreign Assets Control (OFAC) Used for screening customers and beneficial owners and for filtering transactional data

93 c Office of Financial Sanctions ImplementationHMT (OFSI) Used for screening customers and beneficial owners and for filtering transactional data

93 d European Union Consolidated List (EU) Used for screening customers and beneficial owners and for filtering transactional data

93 e Lists maintained by other G7 member countriesUsed for screening customers and beneficial owners and for filtering transactional data

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Wolfsberg Group Corresponden Banking Due Diligence Questionnaire (CBDDQ) V1.2

93 f Olher (specify)

94 When new entities and natural persona areadded to sanctions lists, how many businessdays before the Entity updates its lists?

Same day to 2 days

95 When updates or additions to the SanctionsLists are made, how many business daysbefore the Entity updates their active manualand / or automated screening system against:

95 a Customer Data after 6 or more days

95 b Transactionssame day

96 Does the Entity have a physical presence, e.g.,branches, subsidia es, or representative officeslocated in countries/regions against hich UN,OFAC, OFSI, EU and G7 membercountrieshave enacted comprehensivejurisdiction-basedSanctions?

No

97 Confirm that all responses provided in theabove Section SANCTIONS are representativeof all the LE's branches

Yes



11. TRAINING & EDUCATION98 Does the Entity provide mandatory training,

which ineludes:

98 a Identification and reporting of transactions togovemment authorities Yes

98 b Examples of different forms of moneylaundering, terrorist financing and sanctionsviolations relevan for the types of producís andServices offered

Yes

98 C Internal policies for controlling moneylaundering, terrorist financing and sanctionsviolations

Yes

98 d New issues that occur in the market, e.g,,significan regulatory actions or new regulations Yes

98 e Conduct and Culture Yes

99 Is the above mandatory training provided to :

99 a Board and Sénior Committee Management Yes

99 b 1 st Line of Defence Yes99 c 2nd Line of Defence Yes99 d 3rd Line of Defence Yes

99 e 3rd parties to which specific FCC activities havebeen outsourced Not Applicable

99 f Non-employed orkers(contractors/consultants) Not Applicable

100 Does the Entity provide AML, GIF & Sanctionstraining that is targeted to specific roles,responsibilities and high risk producís, Servicesand activities?

Yes

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101 Does the Entity provide customised training forAML, GIF and Sanctions staff? Yes

102 Confirm that all responses provided in theaboveSection TRAINING & EDUCATION arerepresentative of all the LE's branches

Yes

102 a If N, clarify whlch questlons the difference/srelate to and the branch/es that this applies to.

102 b If appropriate, provide any additionalInformation / context to the answers in thissection.

12. QUALITY ASSURANCE /COMPLIANCE TESTING103 Are the Entit/s KYC processes and documents

subject to quality assurance testing? Yes

104 Does the Entity have a program wlde risk basedCompliance Testing process (sepárate to theindependent Audit function)? No

105 Confirm that all responses provided in the aboveSection QUALITY ASSURANCE /COMPLIANCE TESTING are representative ofall the LE's branches

Yes

105 a If N, clarify whlch questlons the difference/srelate to and the branch/es that this applies to.

105 b If appropriate, provide any additionalinfor ation / context to the answers in thissection.

13. AUDI 106 In addition to ¡nspections by the government

supervisors/regulators, does the Entity have aninternal audit function, a testing function orother independent third party, or both, thatassesses FCC A L, CTF and Sanctionspolicies and practicas on a regular basis?

Yes

107 How often is the Entity audited on its AML, CTF& Sanctions programme by the following:

107 a Internal Audit Department Yearly

107 b External Third Party Yearly

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108 Does Ihe ¡nternal audit function or olherindependen! third party cover the followingareas:

108 a AML, CTF & Sanctions policy and proceduresYes

108 b KYC / CDD / EDD and underlyingmethodologies Yes

108 c Transaction Moniloring Yes

108 d Transaction Screening including for sanctionsYes

108 e Ñame Screening & List Management Yes

108 f Training & Education Yes

108 g Technology Yes

108 h Governance Yes108 i Reporling/ etrics & anagement Information

Yes

108 j Suspicious Acti ity Filing Yes

108 k Enterprise Wide Risk AssessmentYes

108 I Olher (specify)

109 Are ad erse findings from intemal & externa audit tracked to completion and assessed foradequacy and completeness? Yes

110 Confirm that all responses provided in theaboveSection,AUDIT are representative of allthe LE's branches

Yes



©The Wolfsberg Group 2018 Page16 CBDDQ V1.2


Declaration Statement

Wolfsberg Group Correspondent Banking Due Diligence Questionnaire 2018 (CBDDQ V1.2)

Declaration Statement (To be signed by Global Mead of Correspondent Banking orequivalent position holder AND Group Money Laundering Prevention Officer, Global Mead ofAnti- Money Laundering, Chief Compliance Officer, Global Mead of Financial CrimesCompliance OR equivalent)

andorrabancAGRicoLreig,sa (Bank ñame) is fully committed to the fight against financial

crime and makes every effort to remain in full compliance with all applicable financial crimelaws, regulations and standards in all of the jurisdictions in which it does business and holdsaccounts.

andorra banc AGRicoL reig, sa (Bank ñame) understands the critical importance of having

effecti e and Sustainable Controls to combat financial crime in order to protect its reputationand to meet its legal and regulatory obligations.

andorra banc AGRicoL eig, sa (Bank ñame) recognises the importance of transparency

regarding parties to transactions in international payments and has adopted/is committed toadopting these standards.

andorra banc agricol reig, sa (Bank ñame) further certifies it complies with/is working to

comply with the Wolfsberg Correspondent Banking Principies and the Wolfsberg TradeFinance Principies. The information provided in this Wolfsberg CBDDQ will be kept currentand will be updated no less frequently than on an annual basis.andorra banc agricol reig, sa (Bank ñame) commits to file accurate supplemental

information on a timely basis.

I, Wan lopez urado (eco) (Global Mead of Correspondent Banking or equivalent),

certify that I have read and understood this declaration, that the answers provided in thisWolfsberg CBDDQ are complete and correct to my honest belief, and that I am authorisedto execute this declaration on behalf of andorra banc agricol reig, sa (Bank ñame)

I, Silvia Merino Moreno (MIRO or equivalent), certify that I have read and

understood this declaration, that the answers provided in this Wolfsberg CBDDQ arecomplete and correct to my honest belief, and that I am authorised to execute thisdeclaration on behalf of a dorra banc agricol reig, sa (Bank ñame)

(Signature & Date (DD/MM/YYYY))

02/08/2019 ¿j-v(Signature & Date (DD/MM/YYYY))


Documents

the Wolfsberg Group - Andbank...©The Wolfsberg Group 2018 Page 1 CBDDQ V1.2 Wolfsborg Group Correspondent Banking Due Diligence Questionnaire (CBDDQ) V1.2 11 Provide the full legal