The contents noted herein pertain to the FirstCaribbean International Bank Limited Group of Companies, Subsidiaries and Branches.
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1 The cntents nted herein pertain t the FirstCaribbean Internatinal Bank Limited Grup f Cmpanies, Subsidiaries and Branches. SECTION 1 GENERAL ADMINISTRATIVE INFORMATION 1. Legal and Trading Name: FirstCaribbean Internatinal Bank Limited 2. Date Established: Octber 11, Street Address: Warrens, St. Michael, Barbads 4. Website Address: 5. Name f Parent Cmpany: Canadian Imperial Bank f Cmmerce (CIBC) 6. Address f Parent Cmpany: Cmmerce Curt, Trnt, Ontari, M5L 1A2 Canada 7. Name f Parent Cmpany Stck Exchange and Symbl: Trnt Stck Exchange (TSE) Symbl CM 8. Operating Cmpanies: FirstCaribbean Internatinal Bank Limited perates eight (8) whlly r majrity wned entities as fllws: 1. FirstCaribbean Internatinal Bank (Barbads) Limited (Whlly wned) Address: Michael Mansr Building, Warrens, St. Michael, Barbads Lcatins: Anguilla; Antigua and Barbuda; Barbads; Dminica; Grenada; St. Kitts and Nevis; St. Lucia; St. Vincent and the Grenadines 2. FirstCaribbean Internatinal Bank (Bahamas) Limited (95.21% sharehlding) Address: Shirley Street, Nassau, The Bahamas Lcatins: The Bahamas and Turks and Caics Islands 3. FirstCaribbean Internatinal Bank (Cayman) Limited (Whlly wned) Address: 25 Main St., Gerge Twn, Grand Cayman Lcatins: Aruba, British Virgin Islands, Cayman, Curaca and St. Maarten 4. FirstCaribbean Internatinal Bank (Jamaica) Limited (Whlly wned) Address: Knutsfrd Bulevard, Kingstn, Jamaica Lcatin: Jamaica 5. FirstCaribbean Internatinal Wealth Management Bank (Barbads) Limited (Whlly wned) Address: Michael Mansr Building, Warrens, St. Michael, Barbads Lcatin: Barbads 6: FirstCaribbean Internatinal Bank (Trinidad and Tbag) Limited (Whlly wned) Address: 74 Lng Circular Rad, Maraval, Prt f Spain, Trinidad and Tbag Lcatin: Trinidad and Tbag 7. CIBC Trust Cmpany (Bahamas) Limited (Whlly wned) Address: West Bay Street, Gdmans Bay Crprate Centre, Nassau, The Bahamas Lcatin: The Bahamas 8. CIBC Bank and Trust Cmpany (Cayman) Limited (Whlly wned) Address: CIBC Financial Centre, 11 Dr. Ry s Drive P. O. Bx 694, Gerge Twn, Cayman Islands Lcatin: Cayman Islands 9. Type f Business and Activity: Financial Services including but nt limited t: Retail, Crprate Banking, Capital Markets and Wealth Management
2 10. Is the Financial Institutin Publicly Traded? YES (If Yes, please state name f exchange and symbl) FirstCaribbean Internatinal Bank Limited is itself publicly traded as well as ne (1) f its perating cmpanies, as fllws: FirstCaribbean Internatinal Bank Limited FCI 1. Barbads Stck Exchange 2. Trinidad and Tbag Stck Exchange 3. Eastern Caribbean Stck Exchange FirstCaribbean Internatinal Bank (Bahamas) Limited BISX 1. Bahamas Internatinal Securities Exchange 11. Regulatry Authrity Infrmatin: The FirstCaribbean Grup f Cmpanies is licensed and supervised by the fllwing Regulatry Authrities: FirstCaribbean Internatinal Bank (Barbads) Limited regulatry authrities are: Central Bank f Barbads Eastern Caribbean Central Bank FirstCaribbean Internatinal Bank (Bahamas) Limited regulatry authrities are: Central Bank f the Bahamas Turks and Caics Islands Financial Services Cmmissin FirstCaribbean Internatinal Bank (Cayman) Limited regulatry authrities are: Cayman Islands Mnetary Authrity Central Bank f Curaca and St. Maarten British Virgin Islands Financial Services Cmmissin Central Bank f Aruba FirstCaribbean Internatinal Bank (Curaca) N.V. regulatry authrity is: Central Bank f Curaca and St. Maarten FirstCaribbean Internatinal Bank (Jamaica) Limited regulatry authrities are: Bank f Jamaica Financial Services Cmmissin FirstCaribbean Internatinal Wealth Management Bank (Barbads) Limited regulatry authrity is: Central Bank f Barbads FirstCaribbean Internatinal Bank (Trinidad and Tbag) Limited regulatry authrity is: Central Bank f Trinidad and Tbag
3 CIBC Trust Cmpany (Bahamas) Limited regulatry authrities are: Central Bank f The Bahamas Securities Cmmissin f The Bahamas CIBC Bank and Trust Cmpany (Cayman) Limited regulatry authrity is: Cayman Islands Mnetary Authrity
4 SECTION 2 ANTI-MONEY LAUNDERING/ANTI-TERRORIST FINANCING PROGRAM A. General AML/ATF Plicies, Practices and Prcedures YES NO 1. Des the Financial Institutin s AML/ATF prgram require apprval f the Bard f Directrs? 2. Des the Financial Institutin s apprved AML/ATF prgram include a designated Cmpliance Officer with versight respnsibility fr crdinating the AML/ATF prgram n a daily basis? 3. Des the Financial Institutin s apprved AML/ATF prgram include written plicies, dcumenting the prcesses t be fllwed in preventing, detecting and reprting suspicius activity? 4. Des the Financial Institutin s apprved AML/ATF prgram include an independent internal audit functin that peridically tests the AML/ATF practices and plicies n a regular basis? 5. Des the Financial Institutin have a plicy prhibiting accunts/relatinships with shell banks? (A shell bank is defined as a bank incrprated in a jurisdictin in which it has n physical presence and which is unaffiliated with a regulated financial grup) 6. Des the Financial Institutin s apprved AML/ATF prgram include plicies cvering relatinships with plitically expsed persns cnsistent with industry best practice? 7. Des the Financial Institutin require that its AML/ATF plicies be applied t all branches and subsidiaries f the Financial Institutin bth in the hme cuntry and in lcatins utside f the hme cuntry? 8. Des the Financial Institutin have apprpriate recrd retentin prcedures pursuant t applicable laws? B. Risk Assessment 1. Des the Financial Institutin determine the apprpriate level f due diligence necessary fr thse categries f custmers and transactins that the Financial Institutin has reasn t believe pse a heightened risk f illicit activities at r thrugh the Financial Institutin? C. Knw Yur Custmer Prcedures 1. Has the Financial Institutin implemented systems fr the identificatin f its custmers using independent verifiable surces including: a. Identificatin f beneficial wnership (including wnership and cntrl structure where applicable)? b. Infrmatin regarding the purpses and nature f business relatinship? c. On-ging due diligence f the business relatinship and scrutiny f transactins undertaken t ensure cnsistency with client prfile? d. Prcedures that establish a recrd fr each custmer nting their respective identificatin dcuments at accunt pening? 2. Des the Financial Institutin have a plicy that prhibits custmers frm maintaining annymus accunts (i.e. numbered accunts fr which the Financial Institutin des nt knw the wner? 3. Des the Financial Institutin have a plicy that specifies hw transactins invlving ccasinal custmers shuld be handled? 4. Des the Financial Institutin s Knw Yur Custmer Plicy include enhanced due diligence prcedures fr a. Plitically expsed persns? b. The handling f nn-face-t-face business relatinships? c. The use f intermediaries and ther third party surces f business? D. Reprtable Transactins 1. Des the Financial Institutin have plicies r practices fr the identificatin and reprting f unusual/suspicius transactins?
5 E. Transactin Mnitring YES NO 1. Des the Financial Institutin have prcedures t identify transactins that are structured t avid large cash reprting requirements? 2. Des the Financial Institutin mnitr transactins against fficial lists f suspect terrrists and/r terrrist rganizatins and are cnfirmed matches reprted t cmpetent authrities? 3. Des the Financial Institutin have a mnitring prgram fr suspicius r unusual activity that cvers funds transfers and mnetary instruments (e.g. traveler s cheques, mney rders, etc.)? 4. Des the Financial Institutin require cmplete infrmatin fr utging wire transfer instructins, including sender and beneficiary names, addresses, accunt numbers and purpse? F. AML/ATF Training 1. Des the Financial Institutin prvide AML/ATF training t staff n a regular basis that includes: a. Knw Yur Custmer Prcedures? b. The means f identifying unusual/suspicius activity and internal prcedures t reprt same? c. Examples f mney laundering and terrrist financing? d. Internal prcedures t detect and prevent mney laundering and terrrist financing? 2. Des the Financial Institutin maintain recrds f executed training including attendance recrds and training materials used? 3. Des the Financial Institutin cmmunicate new AML/ATF laws r regulatins r changes t existing laws r regulatins t relevant emplyees? Anti-Mney Laundering and Anti-Terrrist Financing Questinnaire
6 Cmpliance Cntact Infrmatin: The Chief Cmpliance Officer (CCO) is Candice Huggins: The Chief Anti-Mney Laundering Officer (CAMLO) is Annetta Francis: Fr further infrmatin regarding the cntents f this AML/AFT questinnaire please cntact the nted Cmpliance persnnel f the respective perating cmpanies: FirstCaribbean Internatinal Bank (Bahamas) Limited Randy Taylr Tel: (242) ; Randy.Taylr@cibcfcib.cm FirstCaribbean Internatinal Bank (Barbads) Limited Inga Millingtn Tel: (246) ; Inga.Millingtn@cibcfcib.cm Tracee Bascmbe Tel: (246) ; Tracee.Bascmbe@cibcfcib.cm FirstCaribbean Internatinal Bank (Cayman) Limited Cayman, St. Maarten & Aruba: Elvis Cward Tel: (345) ; Elvis.Cward@cibcfcib.cm BVI: Hugh Henry Tel: (268) ; Hugh.Henry@cibcfcib.cm Curaca: Rynell Martijn Tel: (5999) ; Rynell.Martijn@cibcfcib.cm FirstCaribbean Internatinal Bank (Jamaica) Limited Judith Rme Tel: (876) ; Judith.Rme@cibcfcib.cm FirstCaribbean Internatinal Wealth Management Bank (Barbads) Limited Tracee Bascmbe Tel: (246) ; Tracee.Bascmbe@cibcfcib.cm FirstCaribbean Internatinal Bank (Trinidad and Tbag) Limited Cindy Sadaphal Tel: (868) ; Cindy.Sadaphal@cibcfcib.cm CIBC Bank and Trust Cmpany (Cayman) Limited Reina Ebanks Tel: (345) ; Reina.Ebanks@cibcfcib.cm CIBC Trust Cmpany (Bahamas) Limited Natika Whitfield Tel: (242) ; Natika.Whitfield@cibcfcib.cm Anti-Mney Laundering and Anti-Terrrist Financing Questinnaire
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