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反洗钱调查问卷中英文翻译版本模板---转载吧!懒人

发布时间:2016-03-11 16:57:36
 

反洗钱调查问卷中英文翻译版本模板,联系我购买

If you answer “No” to any question, additional information can be supplied at the end of the questionnaire. 

I.  General AML/ATF Policies, Practices and Procedures

YES

NO

1.     Does your company’s AML/ATF program require approval of the Board of Directors?

2.     Does your company’s approved AML/ATF program include a designated Compliance Officer with oversight responsibility for coordinating the AML/ATF program on a daily basis?

3.     Does your company’s approved AML/ATF program include written policies documenting the processes to be followed in preventing, detecting and reporting suspicious activity?

4.     In addition to inspections by the Government supervisors/regulators, does your company’s approved AML/ATF program include an independent internal audit function that assesses the AML/ATF practices and policies on a regular basis?

5.     Does your company 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 your company 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 your company’s approved AML/ATF program include policies covering relationships with politically exposed persons, their families and close associates consistent with industry best practice?

8.     Does your company require that its AML/ATF policies be applied to all branches and subsidiaries of your company both in the home country and in locations outside of the home country?

9.     Does your company have appropriate record retention procedures pursuant to applicable laws?

II.  Risk Assessment

YES

NO

10.  Does your company determine the appropriate level of due diligence necessary for those categories of customers and transactions that your company has reason to believe pose a heightened risk of illicit activities at or through your company?

11.  Does your company have a risk-based assessment of its customer base and their transactions?

III.  Know Your Customer Procedures

YES

NO

12.  Has your company implemented systems & processes for the identification and verification of its customers using independent verifiable sources including:

 

a.     Identification of beneficial ownership (including ownership and control structure where applicable)?

 

b.     Information regarding the purposes and nature of the business relationship?

 

c.     On-going due diligence of the business relationship and scrutiny of transactions undertaken to ensure consistency with client profile?

 

d.     Procedures that establish a record for each customer noting their respective identification documents at account opening?

 

e.     Procedures to identify and verify source of funds especially in the case of international transfer requests?

13.  Does your company assess its customers’ AML policies or practices?

14.  Does your company’s “Know Your Customer” procedures allow customers to maintain anonymous accounts (i.e. numbered accounts for which your company does not know the owner?

15.  Does your company have a policy that specifies how transactions involving occasional customers should be handled?

16.  Does your company’s “Know Your Customer” Policy include enhanced due diligence procedures for

 

a.     Politically Exposed Persons?

 

b.     The handling of non-face-to-face business relationships

 

c.     The use of intermediaries and other third party sources of business?

17.  Does your company complete a risk-based assessment to understand the normal and expected transactions of its customers?

IV.  Reportable Transactions

YES

NO

18.  Does your company have policies or practices for the identification and reporting of unusual/suspicious transactions that are required to be reported to the authorities? 

 

 

 

V.  Transaction Monitoring

YES

NO

19.  Does your company have procedures to identify transactions that are structured to avoid large cash reporting requirements?

20.  Does your company monitor transactions against official lists of known or suspected terrorists and/or terrorist organizations and are confirmed matches reported to competent authorities?

21.  Does your company have a monitoring program for suspicious or unusual activity that covers funds transfers and monetary instruments (e.g. traveler’s cheques; money orders etc)?

22.  Does your company require complete information for outgoing wire transfer instructions, including sender and beneficiary names, addresses, account numbers and purpose?

23.  Does your company have policies to reasonably ensure that it only operates with correspondent banks that possess licenses to operate in their countries of origin?

VI.  AML/ATF Training

YES

NO

24.  Does your company provide AML/ATF training to staff on a regular basis that includes:

 

a.     “Know Your Customer” Procedures

 

b.     The means of identifying unusual/suspicious activity and internal procedures to report same

 

c.     Examples of different forms of money laundering and terrorist financing involving your company’s products and services

 

d.     Internal procedures to detect and prevent money laundering and terrorist financing

 

25.  Does your company maintain records of executed training including attendance records and training materials used?

26.  Does your company communicate new AML/ATF laws or regulations or changes to existing laws or regulations to relevant employees?

27.  Does your company employ third parties to carry out some of the functions of your company?

28.  If the answer to question 27 is ‘Yes’, does your company  provide training to the relevant third parties that includes:

 

a.     “Know Your Customer” Procedures

a.     The means of identifying unusual/suspicious activity and internal procedures to report same

 

b.     Examples of different forms of money laundering and terrorist financing involving your company’s products and services

 

c.     Internal procedures to detect and prevent money laundering and terrorist financing

 

 

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