合规(反洗黑钱和反恐融资)
反洗钱和反恐融资(AML/CFT)问答卷
GENERAL AML POLICIES, PRACTICES AND PROCEDURES
叙述
是/否
Is the AML compliance program approved by the FI’s board or a senior committee?
是
Does the FI have a legal and regulatory compliance program that includes a designated officer that is responsible for coordinating and overseeing the AML framework?
是
Has the FI developed written policies documenting the processes that they have in place to prevent, detect and report suspicious transactions?
是
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 AML policies and practices on a regular basis?
是
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.)
是
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?
是
Does the FI have policies covering relationships with Politically Exposed Persons (PEP’s), their family and close associates?
是
Does the FI have record retention procedures that comply with applicable law?
是
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?
是
RISK ASSESSMENT
叙述
是/否
Does the FI have a risk-based assessment of its customer base and their transactions?
是
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?
是
KNOW YOUR CUSTOMER, DUE DILIGENCE AND ENHANCED DUE DILIGENCE
叙述
是/否
Has the FI implemented processes for the identification of those customers on whose behalf it maintains or operates accounts or conducts transactions?
是
Does the FI have a requirement to collect information regarding its customers’ business activities?
是
Does the FI assess its FI customers’ AML policies or practices?
是
Does the FI have a process to review and, where appropriate, update customer information relating to high risk client information?
是
Does the FI have procedures to establish a record for each new customer noting their respective identification documents and ‘Know Your Customer’ information?
是
Does the FI complete a risk-based assessment to understand the normal and expected transactions of its customers?
是
REPORTABLE TRANSACTIONS AND PREVENTION AND DETECTION OF TRANSACTIONS WITH ILLEGALLY OBTAINED FUNDS
叙述
是/否
Does the FI have policies or practices for the identification and reporting of transactions that are required to be reported to the authorities?
是
Where cash transaction reporting is mandatory, does the FI have procedures to identify transactions structured to avoid such obligations?
是
Does the FI screen customers and transactions against lists of persons, entities or countries issued by government/competent authorities?
是
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?
是
Does the FI adhere to the Wolfsberg Transparency Principles and the appropriate usage of the SWIFT MT 202/202COV and MT 205/205COV message formats?1
是
TRANSACTION MONITORING
叙述
是/否
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?
是
AML TRAINING
叙述
是/否
Does the FI 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 FI’s products and services. - Internal policies to prevent money laundering.
是
Does the FI retain records of its training sessions including attendance records and relevant training materials used?
是
Does the FI communicate new AML related laws or changes to existing AML related policies or practices to relevant employees?
是
Does the FI employ third parties to carry out AML functions?
否
If the answer to question 27 is yes, does the FI provide AML 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.
名字 : Mr. James Edwin John
职称 : Head of Financial Crime
地址 : Level 22, Menara Hong Leong,
No. 6, Jalan Damanlela,
Bukit Damansara, 50490,
Kuala Lumpur, Malaysia
电话: +603-2081 8888
传真: +603-20818919
日期: 16th November 2022
1 需要遵守的四个支付信息准则为:i)金融机构不应该为了规避其它金融机构在支付过程检测某项信息,而忽略,删除,或更改该项付款信息或订单资料; ii)金融机构不应该为了规避其它金融机构在支付过程检测某项信息,而使用任何特定支付信息; iii)在遵守适用法律的前提下,金融机构应该在付款过程中与其他金融机构充分合作,提供有关当事方的相关须要信息; (iv)金融机构应强烈鼓励其代理银行遵守这些则。资源:https://www.wolfsberg-principles.com/sites/default/files/wb/pdfs/wolfsberg-standards/13.%20Wolfsberg_NYCH_Statement_on_Payment_Message_Standards_%282007%29.pdf