NBB_2017_15 Page 1 of 23

Transcription

1 1. General infrmatin (nly t be cmpleted by institutins gverned by Belgian law r freign institutins with a branch in Belgium) 1.1. Institutin name: 1.2. Type f institutin: Institutin gverned by Belgian law: 1.3. Address f registered ffice (r address f the branch): 1.4. CBE number: 1.5. Please indicate whether yur institutin acts as a parent cmpany / stand-alne institutin in Belgium, r whether it perates as part (subsidiary, branch, establishment) f a grup in Belgium: 1.6. (i) Sharehlder structure f yur institutin r, if yur institutin is part f a grup, (ii) the sharehlder structure f its ultimate parent cmpany 1 + the percentage f shares held: Branch in Belgium f a freign (EU) institutin: Parent cmpany / Stand-alne cmpany: Part (subsidiary, branch, establishment) f a grup: Type Listed: % Private: % Public: % Other (please specify): % 1.7. Member f the statutry gverning bdy (r, Name: where apprpriate, the management cmmittee) Functin: respnsible at the highest level fr prper cmpliance with the Belgian AML/CFT legislatin: Telephne number: address: 1.8. Cmpliance Officer: Name: Telephne number: address: 1.9. Persn respnsible fr AMLF/CFT: Name: Telephne number: Percentage f shares 1 Definitin f 'grup': a grup f cmpanies cnsisting f a parent cmpany, its branches, its subsidiaries and the entities in which the parent cmpany r its subsidiaries has/have a participating interest, as well as the cmpanies related t each ther within the meaning f Article 22 f Directive 2013/34/EU f the Eurpean Parliament and f the Cuncil f 26 June 2013 n the annual financial statements, cnslidated financial statements and related reprts f certain types f undertakings. NBB_2017_15 Page 1 f 23

2 1.10. Number f FTEs emplyed in yur institutin (acrss departments; branches shuld nly reprt the number f FTEs active in Belgium): Number f FTEs emplyed in the cmpliance functin (bth internal and external staff members; branches shuld nly reprt the number f FTEs active in Belgium): Number f FTEs within the cmpliance functin dedicated t AML/FT (bth internal and external staff members; branches shuld nly reprt the number f FTEs active in Belgium): address: 2. General infrmatin (nly t be cmpleted by the central cntact pints (CCPs) f freign institutins perating in Belgium thrugh agents r distributrs free prvisin f services) 2.1. Name f the institutin represented by yu as a CCP in Belgium: 2.2. Name and cntact details f the CCP (persn respnsible fr AML/CFT): 2.3. Sharehlder structure f the cmpany which is represented by yu in Belgium and fr which yu act as a CCP: Name: CBE number (if the CCP is a legal persn): Address in Belgium: Telephne number in Belgium: address: Type Listed: % Private: % Public: % Other (please specify): % Percentage f shares NBB_2017_15 Page 2 f 23

3 3. Gegraphical presence Ntes / Cmments 3.A. Institutins gverned by Belgian law (nly t be cmpleted by institutins gverned by Belgian law) 3.1. Branches utside Belgium but within the EU as at 31/12/2016: Number: Lcatins (please mentin the member states where the branches are established): 3.2. Branches utside the EU as at 31/12/2016: Number: Lcatins (please mentin the member states where the branches are established): 3.3. Agents/distributrs in Belgium as at 31/12/2016: Number: 3.4. Agents/distributrs utside Belgium but within the EU as at 31/12/2016: 3.5. Agents/distributrs utside the EU as at 31/12/2016: 3.6. Agents/distributrs established in a cuntry included in the list f cuntries in Annex 1 as at 31/12/2016: Number: Lcatins (please mentin the member states where the agents are established): Number: Lcatins (please mentin the cuntries where the agents are established): Number: Lcatins (please mentin the cuntries where the agents are established): 3.7. In the fllwing table, please indicate hw many agents/distributrs are established as at 31/12/2016 in (i) a high-risk cuntry, (ii) a sanctined cuntry r (iii), an ffshre cuntry, as included in Annex 1 (please add additinal lines if the number f such cuntries exceeds 5): Cuntry: Number f agents: 3.8. Subsidiaries in Belgium perfrming an activity in the financial sectr 2 as at 31/12/2016: Number: 2 Institutins hlding a legal status that places them under the supervisin f the NBB r the FSMA. NBB_2017_15 Page 3 f 23

4 3.9. Subsidiaries within the EU perfrming an activity in the financial sectr 3 as at 31/12/2016: Subsidiaries utside the EU perfrming an activity in the financial sectr 4 as at 31/12/2016: Number: Lcatins (please mentin the member states where the subsidiaries are established): Number: Lcatins (please mentin the cuntries where the subsidiaries are established): If yur institutin is part f a grup, please annex a schematic representatin f the grup structure t this dcument which includes the necessary gegraphical infrmatin (lcatins) f the different entities f the grup structure, including the activities carried ut by branches, agents r ther structures that are nt legal persns. 3.B. Branches f freign institutins and institutins perating in Belgium thrugh agents r distributrs (nly t be cmpleted by the branches in Belgium f freign institutins and by the central cntact pints f freign institutins perating in Belgium thrugh agents r distributrs) Number f agents, agencies r distributrs in Belgium as at 31/12/2016: Please annex a schematic representatin f the grup structure t this dcument which includes the necessary gegraphical infrmatin (lcatins) f the different entities f the grup structure, including the activities perfrmed by branches, agents r ther structures which are nt legal persns Des the institutin represented by yu have a physical presence in ne f the cuntries YES included in Annex 1 as at 31/12/2016? NO N/A 4. E-mney activities Ntes / Cmments 4.1. Please indicate which general activities are A. Issuance f electrnic mney effectively perfrmed by yur institutin as at 31/12/2016 (activities fr which yur cmpany has received authrisatin but B. Distributin/redemptin f electrnic mney which are nt actually perfrmed, need nt be mentined): Nt applicable (nt authrised as an electrnic mney institutin) 3 4 Institutins hlding a similar legal status as set ut in ftnte 2. Institutins hlding a similar legal status as set ut in ftnte 2. NBB_2017_15 Page 4 f 23

5 5. Payment services Ntes / Cmments 5.1. Please indicate which payment services are effectively perfrmed by yur institutin as at 31/12/2016 (activities fr which yur cmpany has received authrisatin but which are nt actually perfrmed, need nt be mentined). 1. Services enabling cash t be placed n a payment accunt as well as all the peratins required fr perating a payment accunt; 2. Services enabling cash withdrawals frm a payment accunt as well as all the peratins required fr perating a payment accunt; 3. Executin f payment transactins, including transfers f funds n a payment accunt with the user's payment service prvider r with anther payment service prvider; executin f direct debits, including ne-ff direct debits, executin f payment transactins thrugh a payment card r a similar device, executin f credit transfers, including standing rders; 4. Executin f payment transactins where the funds are cvered by a credit line fr a payment service user; executin f direct debits, including ne-ff direct debits, executin f payment transactins thrugh a payment card r a similar device, executin f credit transfers, including standing rders; 5. Issuing and/r acquiring f payment instruments; 6. Mney remittance; 7. Executin f payment transactins where the cnsent f the payer t execute a payment transactin is given by means f any telecmmunicatin, digital r IT device and the payment is made directly t the telecmmunicatin services, IT system r netwrk peratr, wh acts nly as an intermediary between the payment service user and the supplier f the gds and services; NBB_2017_15 Page 5 f 23

6 6. Ancillary activities Ntes / Cmments 6.1. Please indicate whether r nt this ancillary activity is effectively perfrmed by yur institutin as at 31/12/2016 (if yu are authrised t perfrm this activity but yu d nt actually d s, yu shuld nt check the bx): Granting credit related t the payment services as referred t in pints 4, 5 r 7 abve (see questin 5.1) 7. Netwrk f agents (nly t be cmpleted by institutins prviding mney transfer (mney remittance) Ntes / Cmments services) Nte: yur institutin's answers shuld nly take int accunt activities carried ut in Belgium As at 31/12/2016, des yur institutin wrk nly with exclusive agents, nly with nn-exclusive agents, r with bth? Only exclusive agents Only nn-exclusive agents Bth exclusive and nn-exclusive agents Infrmatin nt available 7.2. Please prvide the breakdwn f the number f agents by categry as at 31/12/2016 Number f exclusive agents: Number f nn-exclusive agents: 7.3. Based n the fllwing categries, please indicate which sectrs yur delegated agents primarily perate in as at 31/12/2016 (please prvide an estimate if yu d nt pssess the exact figures, and indicate in the ntes that this is an estimate) Financial sectr (financial services, etc.) % Pstal sectr (Bpst, etc.) % Trade (newsagents, bkshps, night shps, etc.) % Other (please specify in the ntes) % 7.4. Please prvide the percentage f yur delegated agents that have direct access themselves t the sftware applicatin used t perfrm mney transfers as at 31/12/2016? 7.5. With hw many new delegated agents did yur institutin cnclude a cperatin agreement in 2016? 7.6. Please indicate which frmalities are emplyed by yur institutin as at 31/12/2016 fr the affiliatin f new agents? NBB_2017_15 Page 6 f 23

7 Identity card f the agent (r f the managers in case f a legal persn): A certificate f gd cnduct f the agent (r f the managers): The agent's articles f assciatin if the agent is a legal persn: The ultimate (ecnmic) beneficial wner f the legal persn if the agent is a legal persn: Verificatin f the agent's bank accunt t be used in the cntext f the cmmercial relatinship: Other (please specify in the ntes): 7.7. Hw many candidate agents did yu refuse in 2016? 7.8. Hw many f the refused agents as referred t in the previus questin were refused by yur institutin fr reasns f integrity r AML/CFT related reasns? 7.9. What AML/CFT training curses are prvided fr new agents befre they are allwed t represent yur institutin fr mney transfers? Seminars / presentatins: Written ntes / assistance (self-study): E-learning: Other: N initial training is prvided: Which type(s) f cntinuus training des yur institutin ffer t the existing netwrk f agents? Seminars / presentatins: Written ntes / assistance (self-study): E-learning: Other: N cntinuus training is prvided: What is the frequency f the cntinuus AML CFT training curses? Quarterly: Biannually: Annually: Other (please clarify in the ntes) Are the delegated agents f yur institutin assessed peridically? YES NBB_2017_15 Page 7 f 23 YES NO

8 7.13. If yu answered 'YES' t the previus questin, what is the frequency f this assessment? Fr hw many agents did yur institutin decide t terminate the cntractual (representative) relatinship in 2016, and fr what reasns? Number f agents rejected fr cmmercial reasns: Number f agents rejected fr infringements/vilatins f the internal prcedures: Number f agents rejected fr reasns f integrity (e.g. reputatin, type f custmers, etc.): Number f agents fr which the relatinship was terminated at the agent's request: Other: Please annex t this questinnaire fr each f yur agents perating in Belgium a table cntaining the fllwing infrmatin per agent: NO N/A - Name f the agent; - Address f the agent (pstal cde + city); - Main activity f the agent, i.e. a shrt descriptin f the agent's main activity (exchange ffice, mney remittance ffice, grcery, mbile phne shp, newsagent, pst pint, etc.); - Ttal f the mney transfers perfrmed and received by the agent in 2016 (sum f the incming and utging payments); - Ttal amunt f the mney transfers perfrmed and received by the agent in 2016 (sum f the ttal amunt f the incming and utging mney transfers); - The average amunt f the mney transfers (incming and utging mney transfers) perfrmed and received by the agent in 2016; - The average amunt f the utging mney transfers perfrmed by the agent in 2016 (i.e. excluding the incming mney transfers received by the agent); - The ttal amunt f all incming and utging transactins t r frm ne f the cuntries included in Annex 1 perfrmed r received by the agent in 2016; - The number f written reprts prepared by each agent in 2016 with the aim f ntifying atypical transactins t the persn respnsible fr AML in the institutin (the number f s-called SARs r Internal Suspicius Activity Reprts). Nte: If yu d nt pssess all f the infrmatin listed abve fr each agent, please include a table which nly cntains the infrmatin available fr every agent, and mentin in the ntes why certain infrmatin is nt NBB_2017_15 Page 8 f 23

9 available. If pssible, please submit this table as an Excel file. Shuld this nt be pssible fr yur institutin, the requested infrmatin may als be submitted t us in anther frmat. 8. Emplyees f yur institutin belnging t first line supervisin Ntes / Cmments 8.1. In 2016, hw many f yur emplyees belnging t first line supervisin received an ral r written warning fr nn-cnfrmity with yur institutin's internal prcedures r fr reasns f integrity? 8.2. In 2016, with hw many f yur emplyees belnging t first line supervisin did yur institutin terminate the emplyment cntract fr nn-cnfrmity with yur institutin's internal prcedures r fr reasns f integrity? 9. Type f custmers Ntes / Cmments Nte: - If yur institutin has a significant number f inactive custmers, yu may specify the number f inactive custmers in the ntes/cmments Ttal number f custmers with whm a permanent business relatinship was initiated as at 31/12/2016: 9.2. Breakdwn f the number f custmers as referred t in 9.1 as at 31/12/2016: number f natural persns: number f legal persns: number f trusts r ther legal arrangements (withut legal persnality): 9.3. Please prvide a breakdwn f yur custmers as referred t in 9.1 by risk categry as at 31/12/2016 (if yu use anther breakdwn, please fill in this infrmatin in a way that mst clsely apprximates the 3 afrementined categries and prvide further clarificatin in the ntes): Number f 'high-risk' custmers: Number f 'medium-risk' custmers: Number f 'lw-risk' custmers: 9.4. Ttal number f ccasinal custmers in 2016: 9.5. Please prvide a breakdwn f yur ccasinal custmers as referred t in 9.4 by risk categry (if yu use anther breakdwn, please fill in this infrmatin in a way that mst clsely apprximates the 3 afrementined categries and prvide further clarificatin in the ntes): Number f 'high-risk' custmers: Number f 'medium-risk' custmers: NBB_2017_15 Page 9 f 23

10 Number f 'lw-risk' custmers: 10. Gegraphical distributin f custmers Ntes / Cmments Number f custmers as at 31/12/2016 wh are nt dmiciled in Belgium r whse registered ffice is nt situated in Belgium: Number f custmers as referred t in 10.1 wh are dmiciled r have their registered ffice utside Belgium but within the EU: Number f custmers as referred t in 10.1 wh are dmiciled r have their registered ffice utside Belgium and utside the EU: Number f custmers as referred t in 10.1 wh are dmiciled r have their registered ffice in (i) a high-risk cuntry, (ii) a sanctined cuntry r (iii), an ffshre cuntry, as included in Annex Give a breakdwn f the number f custmers as referred t in 10.4 per cuntry (please add additinal lines if yur institutin has clients wh are dmiciled r have their registered ffice in mre than 5 f the cuntries mentined in annex 1): Cuntry: Number f custmers: 11. Remtely identified custmers Ntes / Cmments The ttal number f custmers identified remtely by yur institutin as at 31/12/2016: The number f custmers identified remtely by yur institutin in 2016: 12. Third party business intrducers Ntes / Cmments Des yur institutin call n third party business intrducers in rder t cmply with the due YES diligence requirements regarding new custmers (identificatin, verificatin, characteristics n the nature and business purpse f the relatinship)? NO Please prvide the ttal number f new custmers intrduced in 2016 by a third party business NBB_2017_15 Page 10 f 23

11 intrducer: Please indicate which type f third party business intrducers is called n by yur institutin as at 31/12/2016 in rder t intrduce new custmers, and indicate whether r nt these third party business intrducers belng t the same grup as yur wn institutin: Type: Within the grup: Outside the grup: Credit institutins: Life insurance cmpanies: Intermediaries in banking and investment services: Other (please clarify in the ntes) 13. Crrespndent custmers (nly t be cmpleted by institutins gverned by Belgian law r freign institutins with a branch in Belgium) Is yur institutin invlved in crrespndent relatinships with ther financial institutinsrespndents r des it intend t initiate such relatinships? Hw many crrespndent relatinships has yur institutin initiated as at 31/12/2016 with financial institutins-respndents (custmers)? Hw many crrespndent relatinships has yur institutin initiated as at 31/12/2016 with financial institutins-respndents (custmers) established utside the EEA? Hw many crrespndent relatinships has yur institutin initiated as at 31/12/2016 with financial institutins-respndents (custmers) that are established in cuntries included in Annex 1? YES NO N/A Ntes / Cmments 14. Plitically expsed persns (PEPs) Ntes / Cmments Nte: when calculating the number f PEPs, yu shuld nt nly include the number f PEP custmers, but als the number f PEP agents f yur custmers, the number f PEP beneficial wners f yur custmers and the number f PEP beneficial wners f yur custmers' agents Please prvide the fllwing infrmatin regarding PEPs (as at 31/12/2016): Ttal number f PEPs in yur custmer base: Number f PEPs custmers (hlders f prducts) Number f PEPs custmers' agents NBB_2017_15 Page 11 f 23

12 Number f PEPs UBOs (f bth custmers and their agents) Number f PEPs dmiciled utside Belgium: Number f PEPs dmiciled in a cuntry included in Annex 1: 15. Ultimate beneficial wners (UBOs) Ntes / Cmments Please prvide the fllwing infrmatin regarding the ultimate beneficial wners f yur custmers (as at 31/12/2016): Number f UBOs dmiciled utside Belgium: Number f UBOs dmiciled in ne f the cuntries included in Annex 1: 16. Refused custmers Ntes / Cmments Please prvide the fllwing infrmatin regarding persns r entities that fit int yur institutin's custmer acceptance plicy but were refused by yur institutin in 2016 fr AML/CFT related reasns (if the figures prvided by yur institutin nly cver the refusals decided upn by the cmpliance functin r anther cmpetent bdy, please clarify this in the ntes): Ttal number f refused custmers: Number f refused custmers natural persns (including PEPs): Number f refused custmers PEPs: Number f refused custmers legal persns r ther legal arrangements (trusts, etc.): 17. Transactins Electrnic mney (nly t be cmpleted by electrnic mney institutins) Ntes / Cmments Please prvide the ttal amunt f electrnic mney issued by yur institutin in Please prvide the ttal amunt f electrnic mney redeemed by yur institutin in 2016: Please indicate whether the electrnic mney prducts distributed by yur institutin in 2016 meet the criteria set ut belw: The devices distributed by yur institutin can be charged with electrnic mney amunting t 5,000 eurs r mre: The devices distributed by yur institutin allw the custmer t perfrm payments amunting t 2,500 eurs r mre per transactin: The electrnic mney prducts distributed by yur institutin can be charged/recharged using cash: Des yur institutin issue electrnic mney annymusly? (i.e. withut identifying and YES NBB_2017_15 Page 12 f 23

13 verifying the identity f the custmer t whm the electrnic mney is issued in accrdance with the Law f 11 January 1993): If yu answered 'YES' t the previus questin, please prvide the maximum limits applied by yur institutin fr charging annymus electrnic mney: Maximum limit per device if this device cannt be recharged (in eurs): Maximum limit per device per year, if the device can be recharged (in eurs): If yur institutin answered 'YES' t questin 17.4, what is the ttal number f devices distributed annymusly by yur institutin in 2016, and what is the ttal amunt f electrnic mney issued n these devices? Number f electrnic mney devices distributed annymusly: Ttal amunt f mney issued annymusly: D yur institutin's prcedures allw unidentified third parties t charge/recharge electrnic mney devices n behalf f yur custmers? (e.g. recharging an electrnic mney device n behalf f a custmer thrugh a transfer f funds perfrmed by a third party, r thrugh a cash depsit by a third party n the device f the custmer?) Please indicate whether the electrnic mney prducts distributed by yur institutin meet the fllwing criteria: The prducts allws payments between persns: The prduct is accepted as a means f payment by a large number f merchants r pints f sale: The prduct was designed t be used as a means f payment by merchants ffering services r prducts presenting a high mney laundering and/r terrrist financing risk (e.g. nline gambling): The prduct can be used fr crss-brder transactins r can be used in different cuntries: The prduct enables cash withdrawals: NO N/A YES NO N/A NBB_2017_15 Page 13 f 23

14 18. Transactins Payment activities and services Ntes / Cmments Fr each separate payment activity, please prvide the ttal number f transactins perfrmed by yur institutin in 2016, as well as the ttal amunt f these transactins. Where pssible, please als distinguish between subactivities (e.g. fr activity PI3, if pssible, please prvide a further breakdwn by cllecting activity, card transactins, mbile payments). If yur institutin carries ut different subactivities, yu may add additinal lines t prvide the requested data fr multiple subactivities. PI1 PI2 PI3 PI4 PI5 Sub PI1 Sub PI1 Sub PI2 Sub PI2 Sub PI3 Sub PI3 Sub PI4 Sub PI4 Sub PI5 Sub PI5 Number f transactins Crrespnding amunt: NBB_2017_15 Page 14 f 23

15 PI6 PI7 Sub PI6 Sub PI6 Sub PI7 Sub PI7 19. Mney transfers / Mney remittance (nly t be cmpleted by institutins cnducting this activity) Ntes / Cmments Please indicate which means f payment are accepted by yur institutin fr mney transfers: Cash Payment cards (Bancntact, Maestr, etc.) Credit cards (Visa, Mastercard, American Express, etc.) Annymus prepaid cards Nn-annymus prepaid cards Wire transfers Other (please specify in the ntes) Please prvide the ttal number and the ttal amunt f the mney transfers financed with cash in 2016: Number: Amunt: Please prvide the fllwing infrmatin n the payment vlume in 2016: Nte: - 'Natinal payments' refers t payments made within Belgium. - 'Internatinal payments' refers t payments made frm r t a cuntry ther than Belgium (payments made between Belgium and a member state f the Eurpean Ecnmic Area shuld therefre be cnsidered internatinal payments fr the purpses f this reprting). Natinal payments (sum f payments Number f payments: IN & OUT) Vlume (in eurs): Internatinal payments (sum f Number f payments: NBB_2017_15 Page 15 f 23

16 payments IN & OUT) Vlume (in eurs): In the fllwing table, please prvide the vlume and the ttal amunt f the mney transfers (OUT payments) perfrmed by yur institutin in 2016 fr the tp 10 cuntries (based n the vlume f OUT payments): Cuntry Number f OUT payments (vlume) Cumulative amunt f the payments (in eurs): In the fllwing table, please prvide the vlume and the ttal amunt f the mney transfers (IN payments) received by yur institutin in 2016 fr the tp 10 cuntries (based n the vlume f IN payments): Cuntry Number f IN payments (vlume) Cumulative amunt f the payments (in eurs): Please prvide the ttal number and the crrespnding amunt f the mney transfers (OUT payments) perfrmed n behalf f yur custmers in 2016 t a bank accunt r ther type f accunt r (in the case f cash disbursements) t a persn established in a cuntry included in the list f cuntries in Annex 1: NBB_2017_15 Page 16 f 23

17 Number: Amunt: In the fllwing table, please indicate which cuntries were invlved in the payments as referred t in 19.6, as well as the crrespnding cumulative amunt f the payments frm this cuntry (please add additinal lines if the number f such cuntries exceeds 5): Cuntry: Cumulative amunt f the payments (in eurs): Please prvide the ttal number and the crrespnding amunt f the mney transfers (IN payments) received n behalf f yur custmers in 2016 frm a cuntry included in the list f cuntries in Annex 1: Number: Amunt: In the fllwing table, please indicate which cuntries were invlved in the payments as referred t in 19.8, as well as the crrespnding cumulative amunt f the payments frm this cuntry (please add additinal lines if the number f such cuntries exceeds 5): Cuntry: Cumulative amunt f the payments (in eurs): D yur institutin's internal prcedures allw the funds transferred t yur institutin fr the perfrmance f mney transfers in the name and n behalf f yur custmers t be financed by a third party? YES NO N/A Please indicate the number f cash mney transfers (and the crrespnding amunt) amunting t 5,000 eurs r mre were perfrmed by yur institutin in 2016: Number f cash transactins amunting t mre than 5,000 eurs: Crrespnding amunt (in eurs): Please indicate the number f transactins (and the crrespnding amunt) that yur institutin refused t perfrm in 2016 fr AML/CFT related reasns: NBB_2017_15 Page 17 f 23

18 Ttal number f refused transactins: Crrespnding amunt (in eurs): Number f refused transactins t r frm ne f the cuntries included in Annex 1: Crrespnding amunt (in eurs): D yur institutin's internal prcedures allw yur emplyees r yur delegated agents t perfrm mney transfers in their wn name but n behalf f their custmers (e.g. because the custmer des nt pssess all crrect identificatin data?) If yu answered 'NO' t questin 19.13, have yu, in practice, bserved ne f yur emplyees r ne f yur delegated agents perfrming mney transfers in their wn name but n behalf f a custmer? YES NO N/A YES NO N/A If yu answered 'YES' t questin 19.13, please prvide the number and the ttal amunt f the mney transfers perfrmed by the emplyees f yur institutin r yur agents in their wn name but n behalf f a custmer in 2016: Number f mney transfers: Crrespnding amunt: Number f mney transfers perfrmed r received (IN r OUT) by yur clients in 2016 fr an amunt f eur r mre: 20. Exchange activities (nly t be cmpleted by institutins cnducting this activity) Ntes / Cmments Please indicate which means f payment are accepted by yur institutin fr the perfrmance f exchange transactins: Cash Payment cards (Bancntact, Maestr, etc.) Credit cards (Visa, Mastercard, American Express, etc.) Annymus prepaid cards Nn-annymus prepaid cards Wire transfers Other (please specify in the ntes) Please prvide the ttal number and the crrespnding amunt f the exchange transactins financed with cash in 2016: NBB_2017_15 Page 18 f 23

19 Number: Crrespnding amunt: Please prvide the ttal number and the crrespnding amunt f the exchange transactins perfrmed n behalf f yur custmers in 2016 using currencies issued by ne f the cuntries included in Annex 1 (with the exceptin f the eur): Number: Crrespnding amunt: Please prvide a further breakdwn f the amunts prvided in 20.3 acrss the tp 5 currencies issued by ne f the cuntries included in Annex 1 (with the exceptin f the eur): Currency: Number f transactins Crrespnding amunt (in eurs): 21. Transfers f funds Ntes / Cmments Des yur institutin receive fund transfers as referred t in Regulatin 1781/2006 (Regulatin YES 2015/847 as frm 26 June 2017) fr its custmers? NO N/A If yu answered affirmatively t the previus questin, des yur institutin cnsider the receipt f incmplete transfers f funds and/r fund transfers with irrelevant infrmatin t be: Very prblematic: Prblematic: Slightly prblematic: Nt at all prblematic: Nt applicable: Hw many fund transfers did yur institutin receive in 2016 fr which the necessary (relevant) infrmatin was nt included, and fr what amunt? NBB_2017_15 Page 19 f 23

20 Number: Crrespnding amunt in eurs: Fr hw many f the transfers f funds as referred t in the previus questin did yur institutin act as intermediary payment service prvider? What percentage f the ttal number and f the ttal amunt f fund transfers received in 2016 cnsisted f incmplete fund transfers (and/r fund transfers with irrelevant infrmatin)? Percentage f the ttal number: % Percentage f the ttal amunt: % Des yur institutin have infrmatin n the fur main cuntries f rigin f incmplete fund transfers and/r fund transfers with irrelevant infrmatin? YES NO N/A If yu answered 'YES' t the previus questin, please cmplete the fllwing table fr these fur cuntries: Cuntry: Number Amunt % f the ttal number riginating frm the same cuntry % f the ttal amunt riginating frm the same cuntry Hw many ntificatins f suspicius transactins with regard t incmplete fund transfers (and/r fund transfers with irrelevant infrmatin) were sent t the CTIF-CFI in 2016, and fr what amunt? Number: Crrespnding amunt in eurs: NBB_2017_15 Page 20 f 23

21 22. Cases f fraud Ntes / Cmments If pssible, please prvide the fllwing infrmatin regarding the number f fraud cases (card fraud, identity fraud, etc.) fr the transactins perfrmed/prcessed by yur institutin in 2016: Ttal number f transactins perfrmed / prcessed in 2016 knwn by yur institutin: Cumulative amunt f the transactins perfrmed / prcessed in 2016 fr which fraud has been established: Percentage f the transactins perfrmed/prcessed in 2016 fr which fraud has been established (in relatin t the ttal number f transactins perfrmed / prcessed in 2016)? 23. Analysis f atypical transactins Ntes / Cmments Hw many atypical transactins fr which an internal reprt was submitted t the persn respnsible fr AML/CFT were detected by yur institutin in 2016? Hw many f the atypical transactins as referred t in 23.1 were detected by first-line mnitring (the staff maintaining cntact with custmers) and by secnd-line mnitring (the autmatic system fr the detectin f atypical transactins)? Number detected by first-line mnitring: Number detected by secnd-line mnitring: What is the ttal number f custmers cvered by the reprts as referred t in 23.1? Hw many f the atypical reprts as referred t in 23.1 pertain t:... 'high-risk' custmers:... 'medium-risk' custmers:... 'lw-risk' custmers: Hw many f the reprts as referred t in 23.1 pertain t cash transactins? Hw many f the reprts as referred t in 23.1 were analysed in 2016 under the respnsibility f the persn respnsible fr AML/CFT in yur institutin? What was the average number f staff (expressed in FTEs) specifically tasked with analysing the afrementined internal reprts in 2016, bth within the department f the persn respnsible fr AML/CFT and in ther departments, but under the directin f the persn respnsible f AML/CFT? NBB_2017_15 Page 21 f 23

22 24. Funds and asset freezing Ntes / Cmments Over the curse f 2016, hw many warnings were handled by yur institutin in relatin t the implementatin f financial embargs and asset freezing rders? Nte: 'warnings' shuld be understd t mean all pssible crrespndence with the lists f sanctins r embargs: bth the warnings generated by yur institutin's autmatic screening tls and the warnings detected by first-line mnitring (in case f manual screening against the lists) Over the curse f 2016, hw many ntificatins fr asset freezing were sent by yur institutin t the FPS Finance Treasury, and what was the ttal amunt (in eurs)? Number: Crrespnding amunt: 25. Ntificatin f suspicius transactins t the CTIF-CFI Ntes / Cmments Over the curse f 2016, hw many ntificatins f suspicius transactins did yur institutin submit t the CTIF-CFI, and what was the ttal amunt f the transactins cvered by these ntificatins? Number: Crrespnding amunt: Hw many f the ntificatins t the CTIF-CFI as referred t in 25.1 pertain t:... 'high-risk' custmers:... 'medium-risk' custmers:... 'lw-risk' custmers: Over the curse f 2016, hw many requests fr infrmatin r ther requests regarding AML/CFT did yur institutin receive cncerning persns that effectively are r were yur custmers, their ultimate beneficial wners, their agents r their cunterparties, depending n whether these requests came frm: The CTIF-CFI: The plice r the curts: NBB_2017_15 Page 22 f 23

23 26. Terminatin f the business relatinship fr AML/CFT related reasns Ntes / Cmments Over the curse f 2016, hw many business relatinships with custmers were terminated by yur institutin fr AML/CFT related reasns? If yur institutin culd nt terminate the business relatinship because f legal prvisins f public plicy r mandatry legal prvisins, r if the terminatin f the business relatinship wuld cause severe and disprprtinate damage t yur custmer, fr hw many f yur business relatinships did yur institutin take ther restrictive measures in 2016? In 2016, hw many f the terminatins as referred t in 26.1 and the ther restrictive measures as referred t in 26.2 regarding business relatinships pertained t: Custmers natural persns: Custmers legal persns r ther legal arrangements: Hw many f the terminatins as referred t in 26.1 and the ther restrictive measures as referred t in 26.2 regarding business relatinships with custmers were the subject f a ntificatin t the CTIF-CFI (ntificatins befre as well as after the terminatin): Please prvide the ttal amunt f assets r funds held f custmers with whm the business relatinship was terminated in 2016 (in eurs): Nte: please prvide the amunt f assets r funds held at the mment f the decisin t terminate the business relatinship In 2016, hw many f the terminatins as referred t in 26.1 and the ther restrictive measures as referred t in 26.2 regarding business relatinships pertained t:... 'high-risk' custmers:... 'medium-risk' custmers:... 'lw-risk' custmers: In 2016, hw many f the terminatins as referred t in 26.1 and the ther restrictive measures as referred t in 26.2 regarding business relatinships pertained t PEPs: NBB_2017_15 Page 23 f 23