Wolfsberg Anti Money Laundering Form – Fill Out and Use This PDF

I. General AML Policies, Practices and Procedures:

Yes

No

1.

Is the AML compliance program approved by the FI’s board or a

Y ο

N ο

senior committee?

2.

Does the FI have a legal and regulatory compliance program

Y ο

N ο

that includes a designated officer that is responsible for

coordinating and overseeing the AML framework?

3.

Has the FI developed written policies documenting the

Y ο

N ο

processes that they have in place to prevent, detect and report

suspicious transactions?

4.

In addition to inspections by the government

Y ο

N ο

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?

5.

Does the FI have a policy prohibiting accounts/relationships

Y ο

N ο

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

Y ο

N ο

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

Y ο

N ο

Exposed Persons (PEP’s), their family and close associates?

8.

Does the FI have record retention procedures that comply with

Y ο

N ο

applicable law?

9.

Are the FI’s AML policies and practices being applied to all

Y ο

N ο

branches and subsidiaries of the FI both in the home country

and in locations outside of that jurisdiction?

II. Risk Assessment:

Yes

No

10. Does the FI have a risk-based assessment of its customer base

Y ο

N ο

and their transactions?

11. Does the FI determine the appropriate level of enhanced due

Y ο

N ο

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 and Enhanced

Yes

No

Due Diligence:

12. Has the FI implemented processes for the identification of those

Y ο

N ο

customers on whose behalf it maintains or operates accounts or

conducts transactions?

13. Does the FI have a requirement to collect information regarding

Y ο

N ο

its customers’ business activities?

14. Does the FI assess its FI customers’ AML policies or practices?

Y ο

N ο

15. Does the FI have a process to review and, where appropriate,

Y ο

N ο

update customer information relating to high risk client

information?

16. Does the FI have procedures to establish a record for each new

Y ο

N ο

customer noting their respective identification documents and

‘Know Your Customer’ information?

17. Does the FI complete a risk-based assessment to understand

Y ο

N ο

the normal and expected transactions of its customers?

IV. Reportable Transactions and Prevention and

Yes

No

Detection of Transactions with Illegally Obtained Funds:

18. Does the FI have policies or practices for the identification and

Y ο

N ο

reporting of transactions that are required to be reported to the

authorities?

19. Where cash transaction reporting is mandatory, does the FI

Y ο

N ο

have procedures to identify transactions structured to avoid

such obligations?

20. Does the FI screen customers and transactions against lists of

Y ο

N ο

persons, entities or countries issued by government/competent

authorities?

21. Does the FI have policies to reasonably ensure that it only

Y ο

N ο

operates with correspondent banks that possess licenses to

operate in their countries of origin?

22. Does the FI adhere to the Wolfsberg Transparency Principles

Y ο

N ο

and the appropriate usage of the SWIFT MT 202/202COV and

MT 205/205COV message formats?1

V. Transaction Monitoring:

Yes

No

23. Does the FI have a monitoring program for unusual and

Y ο

N ο

potentially suspicious activity that covers funds transfers and

monetary instruments such as travelers checks, money orders,

etc?

VI. AML Training

Yes

No

24. Does the FI provide AML training to relevant employees that

Y ο

N ο

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.

25. Does the FI retain records of its training sessions including

Y ο

N ο

attendance records and relevant training materials used?

26. Does the FI communicate new AML related laws or changes to

Y ο

N ο

existing AML related policies or practices to relevant

employees?

27. Does the FI employ third parties to carry out some of the

Y ο

N ο

functions of the FI?

28. If the answer to question 27 is yes, does the FI provide AML

Y ο

N ο

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.