CLIENT PROFILE (KYC) Individuals CONTENTS. 1. Relationship Summary. 2. Beneficial Owner Information. 3. Background: Client Acquisition
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- Elwin Gervais Washington
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1 CLIENT PROFILE (KYC) Individuals CONTENTS 1. Relationship Summary 2. Beneficial Owner Information 3. Background: Client Acquisition 4. Personal Information General 5. Personal Information Employment / Business 6. Personal Information Financial 7. Anticipated Activities 8. Attorney / Signatory 9. Client Risk Classification 10. Signature 11. Guidelines Place & Date: 1
2 Relationship Manager: 1. RELATIONSHIP SUMMARY Customer No: Name of Customer: Other existing relationships with Group: Name of Account Customer no. Business Unit Frequency of account statements: Monthly Quarterly Semi-Annually Annually 2. BENEFICIAL OWNER INFORMATION Is the account holder? the Ultimate Beneficial Owner of the Account an agent for the Beneficial Owner If agent, please explain who the real UBO is and what capacity the account holder is involved: 2
3 3. BACKGROUND: CLIENT ACQUISITION Marketing effort Existing Account Upgraded Customer Introduced by: Existing Client Friend Others (please specify) How long client was known to introducer? < 1 year 1 3 years 3-5 years > 5 years Relationship between Introducer and Client? Friend Blood relation Business Associate Acquaintance Others (please specify) Reason for initiating relationship with Emirates NBD Private Banking (for e.g. better pricing, better service, global investments, regional investments etc): 4. PERSONAL INFORMATION - GENERAL Nationality: Country of Domicile: UAE Resident: Yes No Resident Employment 3
4 Visa Validity From: To: Marital Status: Single Married Divorced Widowed No. of Children: Other Banking Relationships: Bank Name Estimated Relationship Value Banking Since 5. PERSONAL INFORMATION EMPLOYMENT / BUSINESS Employed Name & address of Employer: Self Employed Name & address of Business: Position held Percentage of Ownership 4
5 Total Years in Employment (with current and past Employers) Years in Business Annual Turnover Estimated Annual Turnover Nature of Business including countries in which it operates Estimated Annual Profit Nature of Business including countries in which it operates, no of employees, no of offices etc 6. PERSONAL INFORMATION - FINANCIAL Source of Income Salary Business Earnings Investment Income Others (please specify) Estimated Annual Income < $250K $ K $500K- 1 Million $1-3 Million $3-5 Million >$5 Million Please provide explanation on the Source of Income (for e.g. Business Earnings should be explained as to what his average earnings, investment income should include details of the type of investment etc). 5
6 Source of Wealth (Net Worth) Salary Earnings Business Earnings Gift / Inheritance Investment Income Sale of property Sale of company / business Others (please specify) Estimated Total Net worth (including properties, investments deposits etc.) < $1 Million $1-5 Million $5-10 Million $10-25 Million ```` < $25 - $50 Million < $ Million over $100 Million Estimated Liquid Net worth (deposits and liquid investments) < $1 Million $1-5 Million $5-10 Million $10-25 Million < $25 - $50 Million $ Million over $100 Million Please provide an explanation on the Source of Wealth (for e.g. 20 years savings from salary, sale of residential property in London in 1989 for $5 Million etc.) Property Owned: Yes No If yes, Details of Property (Value, Location, etc.) 6
7 7. ANTICIPATED ACCOUNT ACTIVITIES How will the Account be initially funded? Cash Bank transfer Cheque Deposit Others (please specify) Please provide details (amount, source of cash for deposit, bank details from where money is coming, whether third party transfer and if so reasons for such transfer etc.) Expected eventual size of relationship < $1 Million $1-5 Million $5-10 Million $10-25 Million < $25 - $50 Million < $ Million over $100 Million Anticipated activities in the account 1. Details (regular receiver, country, purpose, size) of regular outward payments from the account (if any) 2. Details of regular deposits (regular sender, country, purpose, size) into the account (of any) 3. Intended use of such regular deposits 7
8 4. Other activities expected in the account (liability, turnover etc) 8. ATTORNEY / SIGNATORY Name Nationality Country of Domicile Date of Birth Relationship with Client/ BO 9. CLIENT RISK CLASSIFICATION Please select the appropriate client risk classification (refer the High Risk Client policy of the Group). Please consider the profile of account holder, joint account holder, POA, Beneficial Owner etc while selecting the risk category of Client. Not a High Risk Client A High Risk Client Client from a High Risk Country Client involved with a High Risk Industry PEP (additionally PEP due diligence form should be completed) Large Relationship (over AED. 20 million) Non-Resident of UAE 1 For Higher Risk Clients, please complete the below sections: a. Please provide the reason behind the classification: (In case of PEP, please complete the PEP Due Diligence Form also; In case of high risk countries, please include the countries involved and the link to the client. In case of high risk industries, please include the list of industries and how the client is linked to these industries). 1 These relationships require compliance assessment and GM-PB approval only if they are associated with high risk country or industry. 8
9 b. Please provide details of your finding from investigation against independent sources / additional documents collected to verify background information. Please attach copy of the additional records collected to verify client background information (for eg: Internet Searches, Annual Reports, Financials, World Check results, reference letters etc). c. Comment on your knowledge of Client s background that has enabled you to assess the client s reputation, including business details, previous relationships and other business interests. Please confirm conducting checks and searches by highlighting against the below tools available and that the findings are summarised in the profile and that relevant printouts are attached to the profile: Random Internet Searches World Check Hot List Database Central Bank Blacklist System 9
10 10. SIGNATURES The above is a true reflection of my knowledge about the above relationship. I recommend that the relationship be established with the bank. Name Signature & Date Recommended By Approved by Team Leader Approved by Market Leader In case of High Risk Clients: Compliance Assessment Approved by GM (PB) In case of PEPs, Approved by GM (CWM) 10
11 11. GUIDELINES Guidelines with respect to completion of Client profile. 1. Separate profile forms should be completed for each beneficial owner. 2. For retired persons, please complete last activity with respect to employment / business. 3. Description should be clear that a person that is not familiar with the situation can understand the background of the client. For eg: terms like inheritance or sale of real estate needs to expanded and explained in detail providing underlying information which includes the details of assets and their value. 4. Please note that the details on employment / business should include sufficient information to make an assessment with respect to exposure to sensitive countries, sensitive industries or possibility of PEP involvement. 5. In case of lack of space, please attach separate report to include additional information. 6. This is an internal use only document and so there is no need to obtain Client signature on the document. 7. While determining the risk of the relationship, please give due consideration to the status of POAs and Signatories of the account also. 8. For higher risk clients, please include details of additional investigations and documentation obtained to verify information. 11
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