Anti-Money Laundering Questionnaire I. General AML
Transcription
Anti-Money Laundering Questionnaire I. General AML
CIMB GROUP HOLDINGS BERHAD (706803-D) Location: Level 13, Menara CIMB, Jalan Stesen Sentral 2, Kuala Lumpur Sentral, 50470 Kuala Lumpur, Malaysia CIMB Group Holdings Berhad is the Financial Holding Company of the Financial Group, as defined and regulated under Malaysia’s Financial Services Act 2013, Islamic Financial Services Act 2013 and the Anti-Money Laundering and Anti-Terrorism Financing Act 2001. CIMB Group Holdings Berhad is listed on Bursa Malaysia Securities (stock code: 1023) Anti-Money Laundering Questionnaire The Attached Questionaire provides an overview of the Group’s policies, practices and preventive efforts to combat money laundering and the financing of terrorism. Where there is a conflict between the Group’’s policies and a foreign reporting institution’s regulatory requirements, the more stringent of the stringent requirement shall prevail. I. General AML Policies, Practices and Procedures: 1. Is the AML 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 AML 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 AML 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 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? II. Risk Assessment 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? Yes Y Y Y Y Y Y Y Y Y Yes Y Y Note 1: For ease of reference, the CIMB Group’s AML/CFT policies, efforts and countermeasures have been categorized based on the The Wolfsberg Group financial services industry principles and questionnaire for Know Your Customer, Anti-Money Laundering and Counter Terrorist Financing policies. All rights in relation to the form and structure of the questions remain with the Group. Page 1 of 6 No No III. Know Your Customer, Due Diligence and Enhanced Due Diligence 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’ AML 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 18. Does the FI have policies or practices for the identification and reporting of transactions that are required to be reported to the authorities? 19. Where cash transaction reporting is mandatory, does the FI have procedures to identify transactions structured to avoid such obligations? 20. Does the FI screen customers and transactions against lists of persons, entities or countries issued by government/competent authorities? 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? 22. 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? V. Transaction Monitoring 23. 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 24. 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. 25. Does the FI retain records of its training sessions including attendance records and relevant training materials used? 26. Does the FI communicate new AML related laws or changes to existing AML related policies or practices to relevant employees? 27. Does the FI employ third parties to carry out some of the functions of the FI? 28. If the answer to question 26 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 moneyPage laundering involving the FI’s 2 of 6 products and services. Internal policies to prevent money laundering. Yes Y No Y Y Y Y Y Yes No Y Y Y Y Y Yes Y No Yes Y No Y Y Y Y Additional information: 1. Sanctions As a responsible member of the international financial community, CIMB Group’s policies require its reporting institutions (RIs) to comply with: 1. International Sanctions by United Nations; 2. Sanctions and orders issued by the Government of Malaysia’s regulators and law enforcement agencies (LEAs) or the RI’s home country regulator; 3. Sanctions by other regulators or LEAs recognised by Malaysia; and 4. Restrictions on international transactions with: • Other entities from countries that have been sanctioned by the US-OFAC, the UK Treasury, the European Union (“EU”), particularly when dealing in international currencies (e.g. USD, EUR, GBP); or • Agent/correspondent banks that adopt their own national or international sanctions. In relation to the High Risk countries, where the Financial Action Task Force (“FATF”) has called for counter measures to be applied, CIMB Group entities will refrain from entering into any business relationship, transaction (whether directly or indirectly) or provide any financial services to designated persons or entities (“designated persons”) including the governments, its agencies financial institutions and government linked companies (GLCs) or persons or entities known to be controlled by such entities. This would include non-residents, non-resident companies and non-resident controlled companies, where ambiguity or opacity of beneficial ownership, may give rise to control by such entities. Restriction on relationships are deemed to include the facilitation, arrangement, facilitation of the entering into or continued participation in any transaction or relationship, including but not limited to remittance services, correspondent banking, agency or partnering agreements. 2. Correspondent Banking Accounts and Relationships: Banking Reporting Institutions within CIMB Group do not permit third parties to directly access nor use correspondent accounts to transact on behalf of others. 3. Contact Information: For more information related to AML/CFT, sanctions or other information, please contact the Group AML Office at: General Line Facsimile Line (General/AML) : +603 2261 8888 : +603 2261 0251 / +603 2261 0249 Group AML Office Representatives: Subramaniam Vayaravasamy, Vice President ([email protected]) Andy Yew Choo Ying , Vice President ([email protected]) Sugantha Muthukrishnan, Asst. Vice President ([email protected]) For specific entities within the Group, please contact the respective AML Compliance Officer as listed in Appendix 1. Page 3 of 6 Appendix 1 CIMB Group Reporting Institution No. - Name of Reporting Institution CIMB Group Holdings Berhad Jurisdiction Malaysia Company Registration Number 706803-D Anti-Money Laundering Compliance Officer Geetha Sivapathasundram [email protected] Ang Swee Leong [email protected] 1 CIMB Bank Berhad Malaysia 13491 - P 2 CIMB Islamic Bank Berhad Malaysia 671380 - H 3 CIMB Bank Berhad, Labuan Offshore Branch Malaysia 13491-P/ 090100D (Licensed Labuan Bank) Subramaniam Vayaravasamy [email protected] Mary Tu Mei Ling [email protected] 4 CIMB Bank (L) Limited Malaysia LL00104 / 930009A (Licensed Labuan Bank) 5 CIMB Commerce Trustee Berhad (formerly “BHLB Trustee Berhad”) Malaysia 313031 - A Private Trust: Tan Ping Ying [email protected] 6 CIMB Islamic Trustee Berhad (formerly “CIMB Trustee Berhad”) Malaysia 167913 - M Corporate Trust: Linda Ong Gaik Bee [email protected] 7 CIMB Futures Sdn Bhd Malaysia 257674 - P Norhanizah Mohd Nor [email protected] 8 CIMB Investment Bank Berhad Malaysia 18417 - M Tan Gua Hui [email protected] 9 CIMB Factor Lease Bhd Malaysia 109053 - D Baharudin Othman [email protected] 10 CIMB Principal Asset Management Berhad Malaysia 304078 - K 11 CIMB Principal Islamic Asset Management Berhad Malaysia 217841 - M Page 4 of 6 Yap Ben Shiow [email protected] No. Name of Reporting Institution Jurisdiction 12 CIMB Trust Ltd Malaysia Company Registration Number LL04054 (Co. No) / LT0035 (Offshore Bkg Licence No.) 13 Touch 'n Go Sdn Bhd Malaysia 406400-X Damian Lim Kwi Hoong [email protected] 14 CIMB Middle East BSC Bahrain 61558 Muhammad Bilal Aslam [email protected] 15 CIMB Investment Bank Berhad, Brunei Darussalam Brunei AGO/RFC/731/06 (Reg Cert of Co. Incorporated outside Brunei Darussalam) Brian Wong Kwai Mun [email protected] 16 CIMB Bank PLC Cambodia Co.1935E/2010 In Vansophea [email protected] 17 CIMB Bank Berhad, Shanghai Branch China 310000500536146 Xu Bin Amy [email protected] 18 CIMB Bank Berhad, Hong Kong Branch Hong Kong F 20376 19 CIMB Securities Ltd (formerly “CIMB Securities (HK) Ltd”) Hong Kong Cert. Incorporation 290697/Business Reg. Certificate 14050536-000 20 CIMB Securities (India) Pvt. Ltd India 21 PT Bank CIMB Niaga Tbk Indonesia Co. Identification nos. U65923MH2012P TC237343 09.03.1.65.14394 (Reg No.) / 249544/U.M.II (License No.) 22 PT CIMB-Principal Asset Management Indonesia Reg Cert (Tanda Daftar Perusahaan) 09.03.1.67.24923 Laura Orpa Tomarere [email protected] 23 PT CIMB Securities Indonesia (formerly “PT CIMB-GK Securities”) Indonesia 09.03.1.67.25789 Achmad Aulia [email protected] Page 5 of 6 Anti-Money Laundering Compliance Officer Cheng Pau Yun [email protected] Rosa Leung [email protected] Shishir Karnik [email protected] Juliana Amelia Nehat [email protected] 24 CIMB Securities Ltd, Korea Branch South Korea Company Registration Number 101-84-06802 25 CIMB Thai Bank, Vientiane Branch Laos 264/ Jor Vor Tor Narong Patwichaichoat [email protected] 26 CIMB Bank Berhad, Singapore Branch Singapore S99FC5759D Wong Foong Har [email protected] 27 CIMB-Principal Asset Management (S) Pte Ltd Singapore 200607208K Neo Wei Chiat [email protected] 28 CIMB Securities (Singapore) Pte Ltd (formerly “CIMB-GK Securities Pte Ltd”) Singapore 198701621D Alvin Seah Kheng Seng [email protected] 29 CIMB Investment Bank (Private) Limited Sri Lanka PV 82537 Anarkali Moonesinghe [email protected] 30 CIMB Securities Ltd, Taiwan Branch Taiwan 53665693 Carol Cheng [email protected] 31 CIMB Thai Bank Public Company Limited Thailand 0107537002338 (Bor Mor Jor.480) Thaphop Kleesuwan [email protected] 32 CIMB Principal Asset Management Company Limited Thailand 0105547164509 Pornpimol Changariyawong [email protected] 33 CIMB Securities (Thailand) Co. Ltd (formerly “BT Securities Ltd”) Thailand 0105542081800 Khun Nakorn Lampaves [email protected] 34 CIMB Bank Berhad, London Branch United Kingdom FC022225 Shaheed Sattar [email protected] 35 CIMB Securities (UK) Ltd (formerly “CIMB-GK Securities (UK) Ltd”) United Kingdom 0271 9607 Helen Cai [email protected] 36 CIMB Securities (USA) Inc. (formerly “CIMB-GK Securities (US) Inc”.) United States 5219 71703 Helen Chin-Luk [email protected] No. Name of Reporting Institution Jurisdiction Last updated: 24 March, 2015 Page 6 of 6 Anti-Money Laundering Compliance Officer Tanny Kang [email protected]