ANTI-MONEY LAUNDERING QUESTIONNAIRE for financial institutions

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ANTI-MONEY LAUNDERING QUESTIONNAIRE for financial institutions Powered By Docstoc
					                       ANTI-MONEY LAUNDERING QUESTIONNAIRE
                                 for financial institutions




Le àl ïàòå:
StateÑî     oration "Bank for Develo ment and Forei   Economic Affairs (Vnesheconombank)"
Address of head office:
Vnesheconombank,Akademika SakharovaPros ekt, 9, Moscow, GSP-6, 107996, RussianFederation
Resident count     :
ÒÜåRussian Federation
Contacts:
Naòe:          Alexander Zelenov
Title:         Director of Financiallnstitutions Department
Telephoïe:     +74952046234
Fax:           +7495721 9354
E-òail:        corrbanking@veb.ru
Address:       Vnesheconombank,Akademika SakharovaProspekt,9, Moscow, GSP-6, 107996,
               Russian Federation
Le àl form:
                 is
Vnesheconombank à state corporation establishedÜóthe RussianFederationand its status,business
purposesand powers are establishedÜó the Federal Law "Îï Bank for Development" of 17.05.2007
NQ 82-FZ. ÒÜåonl owner ofVnesheconombank is the stateofthe Russian Federation.
Vnesheconombank's Board
Vladimir À. Dmitriev -Chairman;
Nikolay N. Kosov -Member ofthe Board, First Deputy Chairman;
Anatoliy Ð. Zabaznov -Member ofthe Board, Deputy Chairman;
SergeyÐ. Lykov -Member ofthe Board, Deputy Chairman;
Alexei Ó. Smimov -Member ofthe Board, Deputy Chairman;
Anatoly Â. Ballo -Member ofthe Board, Deputy Chairman;
Petr Ì. Fradkov -Member ofthe Board, Deputy Chairman;
Vladimir Î. Shaprinskiy -Member ofthe Board, Chief Accountant;
Ser å À. Vasiliev -Member ofthe Board.
1. Does the FI Üàóåà 1egal   and regulatory compliance program that requires        ó           N
   à roval ofthe FI's Board or à senior committee thereof?
2. Does the FI Üàóåà legal and regulatory compliance program that inc1udes          ó [{I       NÎ
   à designatedCompliance officer that is responsiblefor coordinating and
   overseeingthe AML program îï à day-to-day basis,which has Üåån
                                     of
   à roved Ü senior management the FI?
3. Has the FI developed written policies documentingthe processesthat they          ó [{1       NÎ
   Üàóåin place to prevent, detectand report suspicioustransactionsthat has
   Üåånà roved Ü seniormana ement?
4. Does the FI Üàóåself-assessment    proceduresas part of its intemal control      ó [{I       NÎ
   environment to assurecompliance with applicable 1awsand intema1
    olicies?
5. In addition to inspections Üóthe govemmentsupervisors/regulators,     does       ó [{I       NÎ
   the FI client have àn internal audit function or other independentthird
     arty that assessesAML olicies and ractices îï àn annualbasis?
6. Does the FI have à policy prohibiting accounts/re1ationships   with shell        ó [{I       NÎ
   banks?
7. Does the FI have po1iciescovering re1ationships  with politica1ly exposed        ó [{I       NÎ
     ersons consistentwith industry bestpractices?
8. Does the FI have appropriate record retention procedurespursuantto               ó [{I       NÎ
    à licable law?
9. Does the FI have à Code ofConduct and representationsÜótheir                     ó [{I       NÎ
                                                     to
    employeesof their understandingand agreement abide Üóthe Code of
    Conduct includin AML rovisions?
10. Does the FI require that its AML po1iciesand practices Üåapplied to all         ó Î         NÎ
    branchesand subsidiaries of the FI both in the Üîmå country and in
    locations outside ofthe home country?

    Vïeshecoïombaïk   has ïî       braïches.   The subsidiaries     î/
    Vïeshecoïombaïk are subject (î AML legislatioï /or each applicable
    jurisdictioï.
 11. Does the F1Üàóåà ns                     î
                              ocuse assessment Its customer ase.                     ó          N
 12. Does the FI identify Ôå categoriesofcustomers whose transactionsand             ó [{I      NÎ
     banking activities àãåroutine and usual?
 13. Does the FI detennine the appropriateleve1ofenhanced due diligence              ó 0        NÎ
     necessaryfor those categoriesof customersthat the FI has reasonto
        .se       à height       .'1     .it activities at or through the ?

               "'~j'Z;jli);Ñ:×;;:;'.'
 14. Has the FI i~ple~ented systems or t å 1 entification of its customers,             ó       N
     including customer infonnation in the case of recordedtransactions,
     accountopening, etc. (for example; ïàòå, ïatioïality, street address,
     telephoïe ïumber, occupatioï, age/ date î/ birth, ïumber aïd type î/
     valid official ideïtificatioï, as well as the ïàòå î/ the couïtry/state that
     issuedit)?
 15. Does the FI Üàóåà requirementto collect infonnation regarding its                  ó [{I   NÎ
     customers' businessactivities?
                  ,


                                                 its
16. Does th~ FI co]]ect information and assess FI customers' AML policies             ó [{[   NÎ
     or ractlces?
17. Does the FI have proceduresto estabIishà record for eachcustomer                  ó [{(   ND
     noting their respective identification documentsand Know Óour
     Customer Information collected at accountî enin ?
] 8. Does the FI take stepsto understandthe normal and expectedtransactions           ó [{(   ND
                                                    of
     of its customersbasedîï its risk assessment its customers?
19. For le~al entities, does the FI obtain copies ofthe constitutive documents        ó [{(   NÎ
     ofthetr customers?


20. Does the FI have policies or practices for the identification and reporting       ó [{(   ND
    of transactions that àãåre uired to Üåre orted to the authorities?
2]. Does the FI have proceduresto identify transactionsstructuredto avoid             ó [{(   NÎ
    large cashre orting requirements?
22. Does the FI have automatedsystemsto screenal] transactions(originators            ó [([   NÎ
    and beneficiaries) againstlists issuedÜó govemment/intemational
    agenciesof known or suspected     terrorists and narcotics traffickers prior to
    conducting à transaction?
23. Does the FI have policies to ensurethat transactionsàãånot conducted              ó 0     NÎ
    with countries that appearas sanctionedentities îï lists provided Üó
      ovemment/intemational bodies?
24. Does the FI have policies to ensurethat they will not conduct transactions        ó 0     NÎ
    with or îï behalf of shel1banks throu h àn of its accountsîã roducts?
25. Does the FI have po]icies to ensurethat it în]ó operateswith                      ó [{(   ND
    correspondentbanks that possess     ]icensesto operate in their coèntries of
    origin?
    Yes,exceptfor the fiïaïcial iïstitutioïs without baïkiïg liceïse due (î
    their s eci IC status.
26. Does the FI have po]icies to ensèrethat it will not conduct transactions          ó 0     ND
    with or provide downstreamproducts and servicesto other FIs that do not




29. Does the FI provide AML awareness      training to its employeesand agents        ó       N
    that includes identification and reporting of transactionsthat must Üå
    reported to govemment authorities, examplesof di fferent forms of mînåó
    laèndering involving the FIs products and services, intemal policies to
    prevent mînåó laundering as well as the processto report suspicious
    transactions?
30. Does the FI retain records of its training sessionsincluding attendance           ó [{(   NÎ
    records and relevant training materials used?
                                               new
   31. Doesthe FI havepoliciesto communicate laws or changes to        ó0      NÎ
                                  to              and
       existingpoliciesor practices its employees agents?
                             in
   32. Hasthe ÐIparticipated /attended                   AML seminars? ó 0
                                         industry/govemment                    NÎ




                                                               and Foreign Economic
FinancialInstitutionName:State corporation "Bank for Development
Affairs Vnesheconombank"
                        Akademika SakharovaProspekt,9, Moscow,GSP-6,107996,
Location:Vnesheconombank,
RussianFederation
Name:Nikola N. Kosov
Title: Member of the Board, First De u   Chairman
Signature:


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