Compliance with Anti-Money Laundering (AML) and Know-Your-Customer (KYC) Regulations

Financial institutions are required to comply with AML and KYC regulations to prevent financial crimes and maintain a secure customer base. The following questionnaire is designed to gather information about an institution’s customer base, correspondent banking relationships, and operational activities.

Section 1: Customer Base

• Types of customers:
  • Individuals (mass retail, wealth management/premium, private banking)
  • Corporates
  • Banks
  • Correspondents
  • Non-bank financial institutions
  • Government/supranational entities
  • Others
• Number of customers in each category

Section 2: Country Distribution

• Top 5 countries where an institution’s customers are domiciled:
  • Revenue share
  • Profit share
  • Number of customers

Section 3: Correspondent Banking Information

• Maintenance of shell bank relationships (a bank without a physical presence or affiliation with a regulated bank)
• Provision of services to shell banks
• Presence at the address from which it operates
• Performance of payable-through accounts transactions and nested transactions (if yes, explanation of Enhanced Due Diligence (EDD) measures applied)

Section 4: Services for Third Parties

• Transacting in favor of third parties:
  • Verification of their identity

Section 5: Monitoring and Reporting

• Identification of correspondent banks originating from non-cooperative countries and territories as identified by the Financial Action Task Force (FATF)
• Formulation of procedures for ongoing monitoring of activities conducted through such correspondent accounts

Section 6: US Patriot Act Certification

• Has an institution provided a US Patriot Act certification to financial institutions in the USA?

Section 7: Commercial or Wholesale Payment Activity

• Using NBE/NBE Foreign Branches accounts for commercial or wholesale payment activity for other banks (if yes, list of correspondents)

Section 8: Risk Assessment

• Does an institution conduct a risk assessment on its correspondents periodically?

Section 9: FATCA Participation

• Does an institution participate in the United States FATCA law?
• Global Intermediary Identification Number (GIIN) if yes

Section 10: Required Documents

• List of documents to be submitted:
  • Registration certificate
  • License certificate
  • Articles of association
  • KYC/AML/CFT policy outline
  • Latest annual report
  • US Patriot Act certification
  • List of shareholders
  • List of foreign branches and subsidiaries
  • Board of directors’ nationalities
  • Applicable tax form for FATCA purposes

Section 11: Authorized Signatories

• Completed by authorized signatories, who certify the accuracy of the statements made and confirm their authority to execute the questionnaire on behalf of the institution.