44. Do you have policies to screen against economic sanctions lists, consistent with applicable legislation and industry best practice? Y/N
Do you screen customers and transactions against lists of persons, entities or countries issued by government/competent authorities? Y/N
45. Do you have appropriate record retention procedures in accordance with applicable regulation? Y/N
46. Do you require your AML policy/systems and controls to be applied to all branches and subsidiaries in your home jurisdiction and overseas? Y/N
Risk Assessment
47. Do you have a risk focus assessment of your customer base and transactions of your customers? Y/N
48. Do you 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? Y/N
Know Your Customer, Due Diligence and Enhanced Due Diligence
49. Have you implemented systems for the identification of clients when first establishing a relationship with them? Y/N
50. Do you collect information regarding the expected activities of your clients? Y/N
51. Do you keep a record for each client, noting identification documentation when first establishing a relationship with them and on an ongoing basis? Y/N
Suspicious Activities and Law Enforcement Disclosures
52. Do you have systems and controls for the identification of suspicious activities, cash transactions and making mandatory disclosures to the applicable authorities? Y/N
53. Where cash transaction report is mandatory, do you have procedures to identify transactions structured to avoid such obligations? Y/N
54. Do you have a monitoring programme for suspicious or unusual activities that includes fund transfers, early surrenders, termination etc.? Y/N
Training
55.
Do you provide AML training to relevant employees that includes the identification and reporting of suspicious activities/transactions, examples of money laundering that involves the type of products you sell and the internal systems and controls you have in place? Y/N
56. Do you retain training records that include details of the materials used and who has attended? Y/N
57. In addition to staff training at induction, do you conduct regular refresher training and additional training when there are changes to existing law, policies and practices? Y/N
Note: Where partner provides “No” to the above AML questions, please document further explanation in the below:
Further explanation for AML question(s) where the response is “No”
Q# Partner explanation