FINANCIAL INSTITUTIONS KNOW YOUR CUSTOMER / ANTI-MONEY LAUNDERING & COUNTERING THE FINANCING OF TERRORISM QUESTIONNAIRE

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1 FINANCIAL INSTITUTIONS KNOW YOUR CUSTOMER / ANTI-MONEY LAUNDERING & COUNTERING THE FINANCING OF TERRORISM QUESTIONNAIRE Section I General Administrative Information Legal Name of Institution Taiwan Shin Kong Commercial Bank Co., Ltd. Legal Form Company limited by shares SWIFT Address / Website MKTBTWTP; Principal Place of Business (Address) 21F, No.36, Songren Road, Xinyi District, Taipei, Taiwan Registered at / Banking License Banking Bureau, Financial Supervisory Commission, Taiwan; issuing authority date and number 1997/01/01; No.: Does your Institution maintain a physical presence 1 in the licensing country? YES NO Is your institution an agency, branch or subsidiary of a bank with a physical presence? YES NO If yes, please answer the following questions: Name of affiliate / parent company: Shin Kong Financial Holding Company Is affiliate / parent company publicly traded? YES NO If yes, list exchanges and symbols: Taiwan Stock Exchange Corporation; SYMBOL: 2888 Indicate affiliation: agency branch subsidiary Licensing country of affiliate: Taiwan Is your institution a publicly traded entity 2? YES NO If yes, please list the exchanges & symbols: Officer Responsible for Account / Relationship: Ms. Yun Chiueh Lin Telephone No.: EXT.8035 Fax No.: Address:amlkyc@skbank.com.tw Secondary Contact: Ms. Sandra Yen Telephone No.: EXT.8033 Fax No.: Address:amlkyc@skbank.com.tw 1 2 Physical presence means your institution maintains a physical place of business, other than an electronic address, in a country where it is authorized to conduct banking activities, at which it employs at least one employee on a full-time basis and maintains records of its banking activities, and is subject to supervision by the regulators of the country authorizing the institution s license. If your institution is an agency, branch or subsidiary of a publicly traded entity that is listed on one of the exchanges listed in Appendix B, the answer to the question should be Yes. SWIFT: MKTBTWTP Page 1 of 4

2 Section II -KNOW YOUR CUSTOMER / ANTI-MONEY LAUNDERING & COUNTERING THE FINANCING OF TERRORISM CONTROLS Yes No 1.Does the AML CFT, and KYC compliance program require approval of your institution s Board or a senior committee thereof? 2.Does your Institution have a legal and regulatory compliance program that includes a designated Compliance officer that is responsible for coordinating and overseeing the AML program on a day-to-day basis, which has been approved by senior management of the FI? 3.Has your Institution developed written policies documenting the processes that they have in place to prevent, detect and report suspicious transactions that has been approved by senior management? 4.In addition to inspections by the government supervisors / regulators, does your institution s client have an internal audit function or other independent third party that assesses AML policies and practices on a regular basis? 5.Does your Institution 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 your Institution have policies covering relationships with politically exposed persons consistent with industry best practices? 7.Does your Institution have appropriate record retention procedures pursuant to applicable law? 8.Does your Institution require that its AML policies and practices be applied to all branches and subsidiaries of the FI both in the home country and in locations outside of the home country? 9.Does your Institution have a risk focused assessment of its customer base and transactions of its customers? 10.Does your Institution determine the appropriate level of enhanced due diligence necessary for those categories of customers and transactions that your Institution has reason to believe pose a heightened risk of illicit activities at or through the FI? 11.Has your Institution implemented systems for the identification of its customers, including customer information in the case of recorded transactions, account opening, etc. (for example; name, nationality, street address, telephone number, occupation, age/ date of birth, number and type of valid official identification, as well as the name of the country / state that issued it)? 12.Does your Institution have a requirement to collect information regarding its customers business activities? 13.Does your Institution collect information and assess its FI customers AML policies or practices? 14.Does your Institution have procedures to establish a record for each SWIFT: MKTBTWTP Page 2 of 4

3 customer noting their respective identification documents and Know Your Customer Information collected at account opening? 15.Does your Institution take steps to understand the normal and expected transactions of its customers based on its risk assessment of its customers? 16.Does your Institution have policies or practices for the identification and reporting of transactions that are required to be reported to the authorities? 17.Does your Institution have procedures to identify transactions structured to avoid large cash reporting requirements? 18.Does your Institution screen transactions for customers or transactions the FI deems to be of significantly high risk (which may include persons, entities or countries that are contained on lists issued by government/international bodies) that special attention to such customers or transactions is necessary prior to completing any such transactions? 19.Does your Institution 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? (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.) 20.Does your Institution have policies to reasonably ensure that it only operates with correspondent banks that possess licenses to operate in their countries of origin? 21.Does your Institution have a monitoring program for suspicious or unusual activity that covers funds transfers and monetary instruments (such as travelers checks, money orders, etc.)? 22.Does your Institution 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 and internal policies to prevent money laundering? 23.Does your Institution retain records of its training sessions including attendance records and relevant training materials used? 24.Does your Institution have policies to communicate new AML related laws or changes to existing AML related policies or practices to relevant employees? 25.Does your Institution employ agents to carry out some of the functions of the FI and if so does the FI provide AML training to relevant agents 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 and internal policies to prevent money laundering? Yes For all above, please provide comments on any No responses: For Q.25: We do not employ third party to carry out FI functions. No SWIFT: MKTBTWTP Page 3 of 4

4 26.Does your Institution provide payable through accounts? ( if Yes, please comment) Yes No 27.Has your institution had any regulatory or criminal enforcement actions resulting from violations of AML laws or regulations in the last five years? ( if Yes, please comment) Yes No The undersigned, based on his/her best knowledge and belief, certifies that the aforementioned questions were answered considering the existing internal controls of the subject financial institution, and further present an accurate representation of the existing state of the institution s AML, CFT, and KYC internal controls and financial service activities. Signature: Completed by: Mr. Daniel J. Chen Position: Chief Legal Officer Date: Apr. 24, 2017 Name of Institution: Taiwan Shin Kong Commercial Bank Co., Ltd. Address of Institution: 21F, No.36, Songren Road, Xinyi District, Taipei, Taiwan DanielChen@skbank.com.tw SWIFT: MKTBTWTP Page 4 of 4

5 The Wolfsberg Group Anti-Money Laundering Questionnaire 2014/English Financial Institution Name: Taiwan Shin Kong Commercial Bank Co., Ltd. Location: 21F, No.36, Songren Road, Xinyi District, Taipei, Taiwan. This questionnaire acts as an aid to firms conducting due diligence and should not be relied on exclusively or excessively. Firms may use this questionnaire alongside their own policies and procedures in order to provide a basis for conducting client due diligence in a manner consistent with the risk profile presented by the client. The responsibility for ensuring adequate due diligence, which may include independent verification or follow up of the answers and documents provided, remains the responsibility of the firm using this questionnaire. Anti-Money Laundering Questionnaire If you answer no to any question, additional information can be supplied at the end of the questionnaire. I. General AML Policies, Practices and Procedures: Yes 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? The Wolfsberg Group consists of the following leading international financial institutions: Banco Santander, Bank of Tokyo-Mitsubishi UFJ, Barclays, Citigroup, Credit Suisse, Deutsche Bank, Goldman Sachs, HSBC, JP Morgan Chase, Société Générale and UBS which aim to develop financial services industry standards, and related products, for Know Your Customer, Anti-Money Laundering and Counter Terrorist Financing policies. 1

6 The Wolfsberg Group Anti-Money Laundering Questionnaire 2014/English II. Risk Assessment: Yes 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? III. Know Your Customer, Due Diligence and Enhanced Due Diligence: Yes 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 Your 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: Yes 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? 1 V. Transaction Monitoring: Yes 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? 1 The four payment message standards to be observed are: i) FIs should not omit, delete, or alter information in payment messages or orders for the purpose of avoiding detection of that information by any other FI in the payment process; ii) FIs should not use any particular payment message for the purpose of avoiding detection of information by any other FI in the payment process; iii) Subject to applicable laws, FIs should cooperate as fully as practicable with other FIs in the payment process when requesting to provide information about the parties involved; and (iv) FIs should strongly encourage their correspondent banks to observe these principles. Source: The Wolfsberg Group consists of the following leading international financial institutions: Banco Santander, Bank of Tokyo-Mitsubishi UFJ, Barclays, Citigroup, Credit Suisse, Deutsche Bank, Goldman Sachs, HSBC, JP Morgan Chase, Société Générale and UBS which aim to develop financial services industry standards, and related products, for Know Your Customer, Anti-Money Laundering and Counter Terrorist Financing policies. 2

7 The Wolfsberg Group Anti-Money Laundering Questionnaire 2014/English VI. AML Training Yes 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 laundering. Y N Y N Space for additional information: (Please indicate which question the information is referring to.) 22. We only use MT202/MT202cov in our swift system, and we follow the transparency principles. 27. We do not employ third parties to carry out any function. We don t maintain correspondent accounts that could be consider a nested account; neither would allow direct use of the correspondent account by third parties (payable-through account) to transact business on their own behalf. Name: Mr. Daniel J. Chen Title: Chief Legal Officer Signature: Date: Apr. 24, 2017 The Wolfsberg Group consists of the following leading international financial institutions: Banco Santander, Bank of Tokyo-Mitsubishi UFJ, Barclays, Citigroup, Credit Suisse, Deutsche Bank, Goldman Sachs, HSBC, JP Morgan Chase, Société Générale and UBS which aim to develop financial services industry standards, and related products, for Know Your Customer, Anti-Money Laundering and Counter Terrorist Financing policies. 3