Know Your Customer (KYC) & Anti-Money Laundering (AML) Questionnaire

Correspondent Banking

Corporate Information

Financial Institution Name
Full Address
SWIFT Code
GIIN Code
Tax ID
Date of Incorporation
Primary Business Line
Name of the Regulatory Body that oversees the Financial Institution
Is the Financial Institution a Bank?
ABI (Italian Banking Association) code[1]

Ownership Structure[2]

Is the Financial Institution publicly or privately owned?
Please provide the details of the major Shareholders holding more than 25% shares
(shareholders name, % of shares, place of incorporation/place of birth)
Is the Financial Institution or the major Shareholder listed on any Stock Exchange?
(If yes, please indicate the Stock Exchange)
Does a beneficial owner of the relationship exist?
(If yes, please supply the full name and the copy of a valid ID document)

Legal Representative or Authorized Representative or Delegate[3]

Full Name
Place and Date of Birth
Country of Birth
Address and Country of Residence
ID/Passport Number[4]
Issuing Authority
Issue Date
Expiry Date

A.  AML Policies, Practices and Procedures

1.  Is money laundering/terrorism financing considered in the company’s country as a crime? / Yes No
2.  Has the country in which the company is located established Laws/Regulations concerning AML/CFT/KYC? / Yes No
3.  Is the company subject to such Laws/Regulations? / Yes No
4.  Does the AML Compliance program require approval of the company's Board or senior committee thereof? / Yes No
5.  Does the company have a legal and regulatory compliance program according to internal and international laws, rules and standards that includes a designated Compliance Officer that is responsible for coordinating and overseeing the AML program? / Yes No
6.  Has the company developed written policies documenting the processes that they have in place to prevent, detect and report suspicious transactions that have been approved by Senior Management? / Yes No
7.  In addition to inspections by the government, supervisors-regulators, does the company have an internal audit function or other independent third party that assesses AML policies and practices on a regular basis? / Yes No
8.  Does the company have a policy prohibiting accounts/relationships with shell banks? (Shell banks: companies with no physical presence in any country and unaffiliated with a regulated financial group) / Yes No
9.  Does the company have policies covering relationships with politically exposed persons (PEP’s), their family and close associates? / Yes No
10.  Does the company have appropriate record retention procedures pursuant to applicable law? / Yes No
11.  Does the company require that its AML policies and practices be applied to all branches and subsidiaries both in the home country and abroad? / Yes No

B.  Risk Assessment

12.  Does the company have a risk focused assessment of its customer base and transactions of its customers? / Yes No
13.  Does the company determine the appropriate level of enhanced due diligence necessary for those categories of customers and transactions that the company has reason to believe pose a heightened risk of illicit activities at or through the company? / Yes No

C.  Know Your Customer, Due Diligence and Enhanced Due Diligence

14.  Has the company implemented processes for the identification of its customers, including customer information (for example: name, nationality, street address, telephone number, occupation, age/date of birth, number and type of valid official identification, as well as the name of the country/state that issued it)? / Yes No
15.  Does the company have a requirement to collect information regarding its customers’ business activities? / Yes No
16.  Does the company have a process including an analysis related to customers’ beneficial owners (ultimate shareholders)? / Yes No
17.  Does the company assess its company customers’ AML policies or practices? / Yes No
18.  Does the company have a process to review and, where appropriate, update customer information relating to high risk client information? / Yes No
19.  Does the company have procedures to establish a record for each new customer noting their respective ID documents and ‘Know Your Customer’ information? / Yes No
20.  Does the company complete a risk-based assessment to understand the normal and expected transactions of its customers? / Yes No

D.  Transaction Monitoring and Reporting

21.  Does the company have policies or practices for the identification and reporting of transactions that are required to be reported to the authorities? / Yes No
22.  Does the company screen customers and transactions against lists of persons, entities or countries issued by government/competent authorities? / Yes No
23.  Does the company have a monitoring program for unusual and potentially suspicious activity (i.e. funds transfers and monetary instruments)? / Yes No
24.  Is the company obliged to report suspicious transactions to government authorities? / Yes No

E.  AML Training

25.  Does the company provide AML training to relevant employees that includes identification and reporting of transactions that must be reported to government authorities, examples of different forms of money laundering involving the company's products and services and internal policies to prevent money laundering? / Yes No
26.  Does the company retain records of its training sessions including attendance records and relevant training materials used? / Yes No
27.  Does the company have policies to communicate new AML related laws or changes to existing AML related policies or practices to relevant employees? / Yes No
28.  Does the company employ agents to carry out some of its functions? / Yes No
29.  If so, does the company provide AML training to relevant agents that includes identification and reporting of transactions that must be reported to government authorities, examples of different forms of money laundering involving the company’s products and services and internal policies to prevent money laundering? / Yes No

Contact Person

Full Name
Title
Telephone
E-mail Address

Date ___/___/______Signature

______

[1] If applicable.

[2] Skip this section in case of Financial Institution subject to Directive 2005/60/EC of the European Parliament and of the Council of 26 October 2005 on the prevention of the use of the financial system for the purpose of money laundering and terrorist financing.

[3] Skip this section in case of Financial Institution subject to Directive 2005/60/EC of the European Parliament and of the Council of 26 October 2005 on the prevention of the use of the financial system for the purpose of money laundering and terrorist financing.

[4] Please provide a copy of the abovementioned ID document.