Names of members of the board (attach additional sheets, if necessary) Name Designation PEP* (yes/no)
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1 Section 1 - General Information Full Legal Name Registered Address Head Office Address (if different from the above) Telephone Web Address Date & Place of Incorporation / Establishment Registration Number/Date & Place of Registration Operating License Number, Type & Name of Issuer and date Name of Regulator Name and address of external auditor(s) Legal Form Name of CEO Number of employees Swift Address of Institution Name of AML / Compliance officer Name of your Financial Intelligence Unit (FIU) Legal Representative Principal line of business activity Please indicate the percentage of appropriate business activity your institution is involved Business Activity Percentage (%) Personal / Retail Banking Commercial Banking Private Banking Trade Finance Trust / Asset Management Insurance Other (please specify) Purpose / Background of the business relationship with Blom Bank SAL Is your bank part of a Group. If yes, which group? Section 2 - Business Activities List of Affiliates, branches, Agencies or subsidiaries, if any (attach additional sheets, if necessary) Country Type No. of locations Section 3 - Ownership Information Institution publicly held or privately owned Stock exchange name/symbol Amount of share capital List of names of principal shareholders (attach additional sheets, if necessary) Name of Shareholder Ownership interest (%) Country / PEP* (yes/no) Section 4 - Management Information Names of principal officers and directors of institution (attach additional sheets, if necessary) Name Position Years of service / PEP* (yes/no) Names of members of the board (attach additional sheets, if necessary) Name Designation PEP* (yes/no) *PEP - Politically exposed persons are individuals who are or have been entrusted with prominent public functions, for example Head of State or of government, senior politicians, senior government, judicial or military officials, senior executives of state owned corporations, important politically party officials, or their family members or close associates. 1
2 Section 5 - Regulatory Environment Questions 1. Has your country established laws designed to prevent money laundering and terrorist financing and is your institution subject to such laws? If yes, please list the name(s) of your country's relevant law(s) & circular(s)/governing body below: Yes No N/A 2. Is the AML/CFT compliance program approved by the FI's board or a senior committee? Does your bank review those policies and procedures? If Yes, how often are reviewed? Section 6 - General AML policies, practices and procedures Describe the structure of the AML function, including the approximate number of dedicated resources. 3. Does the FI client have an internal audit function or other independent third party that assesses AML/CFT policies and practices on a regular basis? What is the frequency of the independent review? Are there any current material audit findings relating to AML? If so, please describe. When did the most recent AML regulatory examination take place? Describe any material findings. What is the frequency of their review? 4. 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.) 5. 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? 6. Does the FI have policies covering relationships with Politically Exposed Persons (PEP's), their family and close associates? Is screening conducted at client onboarding to identify PEPs and related individuals? Is there automated, ongoing screening of customers and connected parties? What enhanced due diligence/monitoring is conducted for PEPs? 7. Does the FI have record retention procedures that comply with applicable law? For how many years? 2
3 8. 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? How do you communicate and enforce the policy and practices across your network of domestic and foreign offices? 9. 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? 10. Does the FI assess its FI customers' AML policies or practices associated with its correspondent bank customers on the basis of the countries and types of banks served? Section 7 - Risk Assessment 11. Does the FI have a risk-based assessment of its customer base and their transactions? How are clients identified/classified by risk levels? Please describe the customer risk assessment methodology: 12. Does your FI provide a substantial portion of their financial products or services to any of the below market segments : Precious Gem Dealers Commodity Trades/Providers Travel Agencies Government Agencies Government Constructors Embassies and/or Consulates Exchange Dealers Casinos Professional Services Providers (PSP) where a beneficial owner is unknown 13. 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? Please describe the Enhanced Due Diligence. Please describe your procedures for updating and reviewing customer information. What is the frequency of periodic review for clients at different risk levels? (High, Medium, Low) Section 8 - Know Your Customer, Due Diligence and Enhanced Due Diligence 14. Has the FI implemented processes for the identification of those customers on whose behalf it maintains or operates accounts or conducts transactions? Is a consistent KYC approach employed throughout the group? 15. Does the FI have a requirement to collect information regarding its customer's business activities? Is KYC due diligence conducted for all clients? Please describe the process used to verify the identity of the customers. 3
4 16. Does the FI complete a risk-based of its onboarding customer's assessment to understand the normal and expected transactions of its customers? 17. Does the FI have procedures to establish a record for each new customer noting their respective identification documents and "Know Your Customer" information? What is the minimum documentation standard for new customers? Does the bank review source of funds when conducting due diligence on new customers? 18. Does the FI screen customers and transactions against lists of persons, entities or countries issued by government/competent authorities? What lists are customers screened against at onboarding? What lists are existing customers screened against? Please provide details (frequency) : What lists are transactions screened against? Is ongoing/transaction screening automated? What system is used? Section 9 - Transaction Monitoring 19. Does the FI have a monitoring program for unusual and potentially suspicious activity that covers funds transfers and monetary instruments such as traveler's checks, money orders, etc? Is transaction monitoring automated? What system is used? Are cash transactions covered by automated transaction monitoring? If not, how are they monitored? Please provide details & specify if there is an aggregate cash transactions monitoring: Who reviews alerts generated (RMs, Compliance etc.)? How many staff undertakes these reviews? Does the bank have a formal exit process to deal with those customers it deems to no longer be acceptable? 20. Where cash transaction reporting is mandatory, does the FI have procedures to identify transactions structured to avoid such obligations? What are the local thresholds for cash reporting? Describe your monitoring process that you perform in order to detect suspicious activity. Section 10 - Reportable Transactions, Prevention and Detection of Transactions with Illegally Obtained Funds 21. Has the FI developed a written policies documenting the processes that they have in place to prevent, detect and report suspicious transactions? 4
5 22. Does the FI have policies or practices for the identification and reporting of transactions that are required to be reported to the authorities? Briefly describe your policies and procedures for identifying suspicious activity and the process for escalating identified suspicious activity to local law enforcement authority. What is the frequency of training delivered for each employee category? Section 11 - AML Training 23. Does the FI provide AML training to relevant employees that include: - Identification and reporting of transactions they 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. 24. Does the FI retain records of its training sessions including attendance records and relevant training materials used? 25. Does the FI communicate new AML related laws or changes to existing AML related policies or practices to relevant employees? Section 12 - Key Regulatory Issues 26. Does the FI offer anonymous accounts or numbered accounts, for which your bank does not have full particulars of the beneficial owner? 27. Does the FI send transfers or bank transactions on behalf of non-customers, without obtaining proof of identification? 28. Does the FI require full information on the issue of transfers, including the name of the originator and beneficiary, your address and account number? 29. In relation to cross-border correspondent banking and other similar relationships, does the FI gather sufficient information about a respondent institution to understand their business, reputation, quality of supervision and regulatory history? 30. Does the FI have a specific regulation to control the risks associated with the non-face-to face business (phone banking, banking on-line etc.) and relationships through intermediaries or third parties? If yes, please provide details: 31. Does the FI offer "Payable Through Account" (Clear-Through)? (These are accounts of the correspondent Bank that are used directly by third parties to conduct commercial operations or any other form of self-employed.) If the answer is affirmative, provide details of Due Diligence requirements that your bank has implemented with respect to customers who have direct access to the accounts of the Bank correspondent. 32. Does your institution take reasonable steps to obtain information relevant to assess & mitigate money laundering risks associated with your bank's correspondent accounts for other foreign banks (i.e. nested correspondent activity)? 33. Does the FI adhere to the Wolfsburg Transparency Principles and the appropriate usage of the Swift MT 202/202COV and MT 205/205COV message formats? 5
6 Section 13 - General 34. Does the FI employ third parties to carry out some of the functions of the FI? If yes to question 29 does the FI provide AML/CFT training to the relevant third parties, that includes: - Identification and reporting of transactions that must be reported to government authorities. - Examples of different forms of money laundering involving the Customer's products and services. - Internal policies to prevent money laundering. 35. Has your institution been involved in any proceedings of public relevance or sanctioned in relation with money laundering or terrorist financing in the last five year? If so, give details of the reason and the outcome. 36. Is your institution operating under offshore banking license? If yes, please specify. Date of issuance / License of body country. 37. Does your institution have a branch or subsidiary operating under offshore banking license? If yes, please specify. 38. Is your institution a government - owned institution? If yes, please specify. Please inform us in writing as soon as possible of any changes to the data that you have entered on this questionnaire. BLOM BANK SAL - GROUP COMPLIANCE DIVISION regulatory.compliance@blom.com.lb Verdun - Rachid Karami St., BLOM BANK Building P.O.Box: Riad El Solh, Beirut , Lebanon Phone: (961-1) Fax: (961-1)
7 I confirm that I am authorised to complete this document: Name: Position: Date: Institution Stamp: Thank you for your co-operation 7
8 Major Sanctioned Countries Questionnaire BLOM BANK's policy is to fully comply with UN, EU, US and relevant local sanctions. In this regard, BLOM BANK endeavors, among other things, to understand the extent of its clients' activities with certain sensitive or major sanctioned countries. Please provide the following information about your company, the company's group and its affiliates. Additional information may be requested upon review. Section 14 - Sanctions IRAN SANCTIONS STATEMENT / QUESTIONNAIRE benefit of, or on the direction or order of, an Iranian financial institution* or a subsidiary of an Iranian financial institution? If yes, please list the name of each Iranian financial institution or subsidiary thereof. (Financial institution or subsidiary). * For the purposes of this questionnaire, an Iranian financial institution means a body corporate, trust, partnership, fund, unincorporated association or organization, established under the laws of Iran that engages, directly or indirectly, in the business of providing financial services. by any entity located in Iran or reside in or have officies.) B - If yes to part A, does your institution apply enhanced due diligence measures to transactions emanating from or destined to Iran (Iran EDD)? (and if not, provide the expected date of Iran EDD implement) SYRIA SANCTIONS STATEMENT / QUESTIONNAIRE benefit of, or on the direction or order of, a Syrian financial institution* or a subsidiary of a Syrian financial institution? If yes, please list the name of each Syrian financial institution or subsidiary thereof. (Financial institution or subsidiary). * For the purposes of this questionnaire, a Syrian financial institution means a body corporate, trust, partnership, fund, unincorporated association or organization, established under the laws of Syria that engages, directly or indirectly, in the business of providing financial services. by any entity located in Syria or reside in or have officies.) B - If yes to part A, does your institution apply enhanced due diligence measures to transactions emanating from or destined to Syria (Syria EDD)? (and if not, provide the expected date of Syrian EDD implement) 1
9 CUBA SANCTIONS STATEMENT / QUESTIONNAIRE benefit of, or on the direction or order of, a Cuban financial institution* or a subsidiary of an Cuban financial institution? If yes, please list the name of each Cuban financial institution or subsidiary thereof. (Financial institution or subsidiary). * For the purposes of this questionnaire, a Cuban financial institution means a body corporate, trust, partnership, fund, unincorporated association or organization, established under the laws of Cuba that engages, directly or indirectly, in the business of providing financial services. by any entity located in Cuba or reside in or have officies.) B - If yes to part A, does your institution apply enhanced due diligence measures to transactions emanating from or destined to Cuba (Cuba EDD)? (and if not, provide the expected date of Cuba EDD implement) SUDAN SANCTIONS STATEMENT / QUESTIONNAIRE benefit of, or on the direction or order of, a Sudanese financial institution* or a subsidiary of a Sudenese financial institution? If yes, please list the name of each Sudanese financial institution or subsidiary thereof. (Financial institution or subsidiary). * For the purposes of this questionnaire, a Sudanese financial institution means a body corporate, trust, partnership, fund, unincorporated association or organization, established under the laws of Sudan that engages, directly or indirectly, in the business of providing financial services. by any entity located in Sudan or reside in or have officies.) B - If yes to part A, does your institution apply enhanced due diligence measures to transactions emanating from or destined to Sudan (Sudan EDD)? (and if not, provide the expected date of Sudan EDD implement) 2
10 NORTH KOREA SANCTIONS STATEMENT / QUESTIONNAIRE benefit of, or on the direction or order of, a North Korean financial institution* or a subsidiary of a North Korean financial institution? If yes, please list the name of each North Korean financial institution or subsidiary thereof. (Financial institution or subsidiary). * For the purposes of this questionnaire, a North Korean financial institution means a body corporate, trust, partnership, fund, unincorporated association or organization, established under the laws of North Korea that engages, directly or indirectly, in the business of providing financial services. by any entity located in North Korea or reside in or have officies.) B - If yes to part A, does your institution apply enhanced due diligence measures to transactions emanating from or destined to North Korea (North Korea EDD)? (and if not, provide the expected date of North Korea EDD implement) MYANMAR/BURNA SANCTIONS STATEMENT / QUESTIONNAIRE benefit of, or on the direction or order of, a Myanmar/Burnese financial institution* or a subsidiary of a Myanmar/Burnese financial institution? If yes, please list the name of each Myanmar/Burnese financial institution or subsidiary thereof. (Financial institution or subsidiary). * For the purposes of this questionnaire, a Myanmar/Burnese financial institution means a body corporate, trust, partnership, fund, unincorporated association or organization, established under the laws of Myanmar/Burna that engages, directly or indirectly, in the business of providing financial services. by any entity located in Myanmar/Burna or reside in or have officies.) B - If yes to part A, does your institution apply enhanced due diligence measures to transactions emanating from or destined to Myanmar/Burna (Myanmar/Burna EDD)? (and if not, provide the expected date of Myanmar/Burna EDD implement) 3
11 Company Name: Date: Company Address: Completed by: (Name & Title) Company Group Name: (If applicable) 4
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