Location: Level 15, Menara CIMB, Jalan Stesen Sentral 2, Kuala Lumpur Sentral, Kuala Lumpur, Malaysia

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1 CIMB GROUP HOLDINGS BERHAD ( D) Location: Level 15, Menara CIMB, Jalan Stesen Sentral 2, Kuala Lumpur Sentral, Kuala Lumpur, CIMB Group Holdings is the Financial Holding Company of the Financial Group, as defined and regulated under s Financial Services Act 2013, Islamic Financial Services Act 2013 and the Anti-Money Laundering and Anti-Terrorism Financing Act CIMB Group Holdings is listed on Bursa Securities (stock code: 1023) Anti-Money Laundering Questionnaire The Attached Questionaire provides an overview of the Group s policies, practices and preventive efforts to combat money laundering and the financing of terrorism. Where there is a conflict between the Group s policies and a foreign reporting institution s regulatory requirements, the more stringent of the stringent requirement shall prevail. I. General AML Policies, Practices and Procedures: es No 1. Is the AML compliance program approved by the FI s board or a senior committee? 2. Does the FI have a legal and regulatory compliance program that includes a designated officer that is responsible for coordinating and overseeing the AML framework? 3. Has the FI developed written policies documenting the processes that they have in place to prevent, detect and report suspicious transactions? 4. In addition to inspections by the government supervisors/regulators, does the FI client have an internal audit function or other independent third party that assesses AML policies and practices on a regular basis? 5. 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.) 6. 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? 7. Does the FI have policies covering relationships with Politically Exposed Persons (PEP s), their family and close associates? 8. Does the FI have record retention procedures that comply with applicable law? 9. 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? II. Risk Assessment es No 10. Does the FI have a risk-based assessment of its customer base and their transactions? 11. 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? Note 1: For ease of reference, the CIMB Group s AML/CFT policies, efforts and countermeasures have been categorized based on the Wolfsberg Group financial services industry principles and questionnaire for Know our Customer, Anti-Money Laundering and Counter Terrorist Financing policies. All rights in relation to the form and structure of the questions remain with the Group. Page 1 of 5

2 III. Know our Customer, Due Diligence and Enhanced Due Diligence es No 12. Has the FI implemented processes for the identification of those customers on whose behalf it maintains or operates accounts or conducts transactions? 13. Does the FI have a requirement to collect information regarding its customers business activities? 14. Does the FI assess its FI customers AML policies or practices? 15. Does the FI have a process to review and, where appropriate, update customer information relating to high risk client information? 16. Does the FI have procedures to establish a record for each new customer noting their respective identification documents and Know our Customer information? 17. Does the FI complete a risk-based assessment to understand the normal and expected transactions of its customers? IV. Reportable Transactions and Prevention and Detection of Transactions with Illegally Obtained Funds es No 18. Does the FI have policies or practices for the identification and reporting of transactions that are required to be reported to the authorities? 19. Where cash transaction reporting is mandatory, does the FI have procedures to identify transactions structured to avoid such obligations? 20. Does the FI screen customers and transactions against lists of persons, entities or countries issued by government/competent authorities? 21. 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? 22. Does the FI adhere to the Wolfsberg Transparency Principles and the appropriate usage of the SWIFT MT 202/202COV and MT 205/205COV message formats? V. Transaction Monitoring es No 23. Does the FI have a monitoring program for unusual and potentially suspicious activity that covers funds transfers and monetary instruments such as travelers checks, money orders, etc? VI. AML Training es No 24. Does the FI provide AML training to relevant employees that includes: Identification and reporting of transactions that 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. 25. Does the FI retain records of its training sessions including attendance records and relevant training materials used? 26. Does the FI communicate new AML related laws or changes to existing AML related policies or practices to relevant employees? 27. Does the FI employ third parties to carry out some of the functions of the FI? 28. If the answer to question 27 is yes, does the FI provide AML training to 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 FI s products and services. Internal policies to prevent money Page laundering. 2 of 5

3 Additional information: 1. Sanctions As a responsible member of the international financial community, CIMB Group s policies require its reporting institutions (RIs) to comply with: 1. International Sanctions by United Nations; 2. Sanctions and orders issued by the Government of s regulators and law enforcement agencies (LEAs) or the RI s home country regulator; 3. Sanctions by other regulators or LEAs recognised by ; and 4. Restrictions on international transactions with: Other entities from countries that have been sanctioned by the US-OFAC, the UK Treasury, the European Union ( EU ), particularly when dealing in international currencies (e.g. USD, EUR, GBP); or Agent/correspondent banks that adopt their own national or international sanctions. In relation to the High Risk countries, CIMB Group entities will refrain from entering into any business relationship, transaction (whether directly or indirectly) or provide any financial services to designated persons or entities ( designated persons ) including the governments, its agencies financial institutions and government linked companies (GLCs) or persons or entities known to be controlled by such entities. This would include non-residents, non-resident companies and non-resident controlled companies, where ambiguity or opacity of beneficial ownership, may give rise to control by such entities. Restriction on relationships and trasactions are deemed to include the facilitation, arrangement, facilitation of the entering into or continued participation in any transaction or relationship, including but not limited to non-face-to-face- transactions, remittance services, correspondent banking, agency or partnering agreements. 2. Correspondent Banking Accounts and Relationships: Banking Reporting Institutions within CIMB Group do not permit third parties to directly access nor use correspondent accounts to transact on behalf of others. 3. Contact Information: For more information related to AML/CFT, sanctions or other information, please contact the Group AML Office at: General Line : Facsimile Line (General/AML) : / Group AML Office Representatives:, Regional Head Chan ew Ling, Regional Head - AML and Sanction Advisory Chia Kwai Fun, Director yewling.chan@cimb.com kwaifun.chia@cimb.com Page 3 of 5

4 For specific entities within the Group, please contact the respective AML Compliance Officer as listed in Appendix 1. CIMB Group Reporting Institution Appendix 1 No. Name of Reporting Institution - CIMB Group Holdings Jurisdiction Company Registration Number Anti-Money Laundering Compliance Officer D Kwan Keen ew 1 2 CIMB Bank CIMB Islamic Bank P H Kwan Keen ew 3 CIMB Bank, Labuan Offshore Branch P/ D (Licensed Labuan Bank) 4 CIMB Bank (L) Limited LL00104 / A (Licensed Labuan Bank) Rusni Binti Ibrahim rusni.ibrahim@cimb.com 5 CIMB Commerce Trustee (formerly BHLB Trustee ) 6 CIMB Islamic Trustee (formerly CIMB Trustee ) 7 CIMB Investment Bank A M Private Trust: Edmund Kwong Bil Li edmund.kwong@cimb.com Corporate Trust: Linda Ong Gaik Bee linda.ong@cimb.com M Kwan Keen ew 8 CIMB Factor Lease Bhd D Baharudin Othman baharudin.othman@cimb.com 9 CIMB Trust Ltd LL04054 (Co No.) / LT0035 Licensed Trust Company Ailah Binti Samsudin ailah.samsudin@cimb.com 10 Touch 'n Go Sdn Bhd X Fariq Hassan fariq@touchngo.com.my Page 4 of 5

5 No. Name of Reporting Institution 11 CIMB Investment Bank, Brunei Darussalam Jurisdiction Brunei Company Registration Number AGO/RFC/731/06 (Reg Cert of Co. Incorporated outside Brunei Darussalam) Anti-Money Laundering Compliance Officer Brian Wong Kwai Mun 12 CIMB Bank PLC Cambodia Co.1935E/2010 Puthkompheakvattey Chhun 13 CIMB Bank, Shanghai Branch 14 CIMB Bank, Hong Kong Branch China Xu Bin Amy Hong Kong F Betty Mah betty.mah@cimb.com 15 PT Bank CIMB Niaga Tbk Indonesia (Reg No.) / /U.M.II (License No.) Entin Rostini entin.rostini@cimbniaga.co.id 16 CIMB Thai Bank, Vientiane Branch 17 CIMB Bank, Singapore Branch 18 CIMB Investment Bank (Private) Limited Laos 264/ Jor Vor Tor Unchalee Suwannasin unchalee.s@cimbthai.com Singapore S99FC5759D Wong Foong Har foonghar.wong@cimb.com Sri Lanka PV Anarkali Moonesinghe anarkali.moonesinghe@cimb.com 19 CIMB Thai Bank Public Company Limited Thailand (Bor Mor Jor.480) Zethjak Leeyakars zethjak.l@cimbthai.com 20 CIMB Bank, London Branch United Kingdom FC David Attree david.attree@cimb.com 21 CIMB Bank (Vietnam) Limited Vietnam Tran Hai Long hailong.tran@cimb.com Last updated: 13 September 2018 Page 5 of 5