Banco Internacional de Comercio S.A. CORRESPONDENT BANKING DUE DILIGENCE

Transcription

1 Banco Internacional de Comercio S.A. CORRESPONDENT BANKING DUE DILIGENCE

2 Correspondent Banking Due Diligence t Complying with our bank s Anti-Money Laundering and Counter Terrorism Financing policies and procedures we would appreciate if you could answer the following questionnaire. Financial Institution Details. Legal name Trading name(s) Main place of business Banking license Phone Fax Swift Address Name of the principal Directors of your bank Name of your external auditors

3 FRAMEWORK, POLICY AND PROCEDURES Has your institution appointed money laundering reporting officer or other senior official designated to coordinate and monitor the implementation of your institution s AML policies and procedures? If yes, Name Phone Fax E- Mail. Has your institution established written policies, which include the processes to prevent and detect unusual or suspicious activities? Have you implemented an independent testing or internal audit program designated to assess your institution s compliance with internal Anti-Money Laundering policies? Does your institution have a policy to prohibit opening accounts with banks that do not have physical presence in any country? Does your institution have a policy to prohibit opening accounts to customers that may present a high level of money laundering and terrorist financing risk? Does your institution screen account activities against the lists of known or suspected terrorist individuals and organizations notified by competent authorities? Does your country have established laws/regulations against Anti-Money Laundering? Are these policies applicable to all your agencies, branches and subsidiaries? Does your institution apply and recognize GAFI s recommendations? ACTIVITIES & MONITORING Has your institution written policies to establish minimum requisites at the time of opening an account? Does your institution take reasonable measures to verify the information on the source of wealth and the economic activity of the customers? Does your institution maintain records of customers documentation and account files for a long period, say five years? Does your institution establish a minimum due and required diligence to conform customers information? If yes, does it include their social objective, nationality, main directors names/ids and addresses, among others? Does your institution have records that identify each one of the customers? Does your institution have a program to monitor suspicious or unusual activities? Does your institution have policies for the identification and reporting of transactions required to be reported to the authorities?

4 ADDITIONAL INFORMATION. Does your institution have an Anti-Money Laundering employee training? If yes, does it include identification and customers transactions? Does your institution keep evidence of these trainings? Does your institution have as internal policy the cooperation with other financial institutions to face any Anti-Money Laundering or any suspicious activity? Completed by Position Signature Date

5 Contacts CENTRAL OFFICE Miramar Business Center, Bldg. Santa Clara Phone: (+53) / 67, presidencia@bicsa.co.cu BUSSINES MANAGEMENT Miramar Business Center, Bldg. Barcelona Phone: (+53) oneyda@bicsa.co.cu BRANCH OFFICE PLAYA Miramar Business Center, Bldg. Jerusalén Phone: (+53) , /09 viera@bicsa.co.cu BRANCH OFFICE LETTERS OF CREDIT Miramar Business Center, Bldg. Santa Clara Phone: (+53) /67, ivan@bicsa.co.cu BRANCH OFFICE PLAZA May 20th Ave esq. Ayestarán, Plaza de la Revolución, Habana Teléfono: (+53) , , /87, lcuza@bicsa.co.cu BRANCH OFFICE PAYMENT ORDERS Miramar Business Center, Bldg. Barcelona Phone: (+53) /67, gricel@bicsa.co.cu