Welcome To Hong Leong Bank

Compliance

ANTI-MONEY LAUNDERING & TERRORIST FINANCING QUESTIONAIRE

Background of the Bank

1. Institution Name :	HONG LEONG BANK BERHAD
2. Registration / Licence Number :	97141-X
3. Registered Office Address :	Level 8, Wisma Hong Leong, 18, Jalan Perak, 50450 Kuala Lumpur Malaysia
4. Web Address :	www.hlb.com.my
5. Date of registration :	26 October 1934
6. Place of Incorporation :	Sarawak, Malaysia
7. Name of Parent Company :	Hong Leong Financial Group Berhad
8. Country of the Local Authority : • & Regulatory	Bank Negara Malaysia
9. Major Activities :	Banking and Financial Services
10. Telephone Number :	603-21642828
11. Name of External Auditors :	Messrs PricewaterhouseCoopers

Check either ‘Yes' or ‘No' to each question below. If you answer ‘No' to any question, additional information can be supplied at the end of the questionnaire.

I . GENERAL AML POLICIES, PRACTICES AND PROCEDURES

Yes

1.	Is the AMLTF compliance program approved by the FI's board or a senior committee?
2.	Does the FI have a legal and regulatory compliance program that includes a designated officer that is responsible for coordinating and overseeing the AMLTF framework?
3.	Has the FI developed written policies documenting the processes that they have in place to prevent, detect and report suspicious transactions?
4.	In addition to inspections by the government supervisors/regulators, does the FI client have an internal audit function or other independent third party that assesses AMLTF policies and practices on a regular basis?
5.	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.)
6.	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?
7.	Does the FI have policies covering relationships with Politically Exposed Persons (PEP's), their family and close associates?
8.	Does the FI have record retention procedures that comply with applicable law?
9.	Are the FI's AMLTF 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?

II. RISK ASSESSMENT

Yes

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

III . KNOW YOUR CUSTOMER, DUE DILIGENCE & ENHANCED DUE DILIGENCE

Yes

12.	Has the FI implemented processes for the identification of those customers on whose behalf it maintains or operates accounts or conducts transactions?
13.	Does the FI have a requirement to collect information regarding its customers' business activities?
14.	Does the FI assess its FI customers' AMLTF policies or practices?
15.	Does the FI have a process to review and, where appropriate, update customer information relating to high risk client information?
16.	Does the FI have procedures to establish a record for each new customer noting their respective identification documents and ‘Know Your Customer' information?
17.	Does the FI complete a risk-based assessment to understand the normal and expected transactions of its customers?

IV. REPORTABLE TRANSACTIONS AND PREVENTION AND DETECTION OF TRANSACTIONS WITH ILLEGALLY OBTAINED FUNDS

Yes

18.	Does the FI have policies covering relationships with Politically Exposed Persons (PEP's), their family and close associates?
19.	Does the FI have record retention procedures that comply with applicable law?
20.	Are the FI's AMLTF 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?
21.	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?

V. TRANSACTION MONITORING

Yes

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

VI. AML TRAINING

Yes

23.

Does the FI provide AMLTF 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 FI's products and services
•	Internal policies to prevent money laundering

24.

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

25.

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

26.

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

27.

If the answer to question 26 is yes, does the FI provide AMLTF training to 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 FI's products and services.
•	Internal policies to prevent money laundering

VII. SANCTIONS REVIEW

28.	Does the FI maintain business relationships with jurisdictions subject to FATF's call to apply counter-measures to protect the international financial system from the on-going and substantial money laundering and terrorist financing (ML/TF) risks emanating from the jurisdictions (as published in the periodic FATF Public Statement), including private individuals, companies or financial institutions?
29.	If yes, does the FI perform enhanced scrutiny and apply effective counter-measures to protect itself against money laundering and financing of terrorism (ML/TF) risks emanating from these jurisdictions?
30.	In the case of existing business relationships with persons, including legal persons and companies, are these relationships regularly reviewed?
31.	If yes, please state, how often this review takes place -
32.	Does the FI have measures in place to verify the origin of the assets of its clients?
33.	Does the FI perform a higher level of due diligence when dealing with the issue of the beneficial owner?
34.	Particularly regarding legal persons and companies?
35.	Are ‘beneficial owners' subject to identification by means of identity documents?
36.	If the FI has doubts regarding the customer's identity, the origin of assets or the identity of the beneficial owner, will they discontinue the relationship respectively and deny the establishment of a new relationship?