AML/CFTA Questionnaire

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AML/CFTA Questionnaire 03.09.2012 Corporate (complete official) name of the Bank in English Belvnesheconombank Open Joint Stock Company Contracted name of the Bank in English Bank BelVEB OJSC Legal status Open Joint Stock Company Registration number No. 24 Country of registration Date of registration December 12, 1991 Name of registering agency National Bank of the License details (number, issue date, issuing agency) License of the National Bank of the No. 6 dated March 29, 2012 to perform banking operations; Special Permit (License) of the Ministry of Finance of the 02200/2500-124-918 to perform professional and stock exchange transactions with securities; License of the Ministry of Finance of the No. 02200/0065061 dated June 23, 2010 to perform transactions with precious metals and stones. Domicile (registered office) 32, Miasnikova str., 220030 Minsk, Mailing address 32, Miasnikova str., 220030 Minsk, Contact telephone and fax numbers Tel. : +375 17 2186650, +375 17 2092944 Fax :+375 17 2264809 e-mail address office@bveb.minsk.by Website address www.belveb.by BIC and country identifier code (similar unique 153001226 identifier attribute) S.W.I.F.T. BELB BY 2X Unique payer s reference (similar unique 100010078 identification attribute) Authorized share capital Bank BelVEB Authorized Capital is registered at Br 1 174 075 million as at May 7, 2012. Number of employees 2,277 (as of July 1, 2012) Information on founders Ministry of Finance of the Republic of Belarus; Vnesheconombank of the USSR, Moscow

Information on shareholders holding a stake of over 5% in the share capital Information on beneficial owners 1 Information on the Bank s governing bodies (location, structure of governing bodies, and also surnames, first names and patronymics (if applicable) of natural persons sitting on such executive body (bodies)) (now State Corporation for Development and Foreign Economic Affairs (Vnesheconombank); JSC Evrofinance, Commercial Bank Eurobank, Paris (now VTB (France); JSC Atlant, Minsk State Corporation Bank for Development and Foreign Economic Affairs (Vnesheconombank) - 97.52 % Akademika Sakharova Prospekt, 9, Moscow, GSP 6, 107996, Russian Federation State Corporation Bank for Development and Foreign Economic Affairs (Vnesheconombank) - 97.52 % Akademika Sakharova Prospekt, 9, Moscow, GSP 6, 107996, Russian Federation Supervisory Board: Petr Fradkov Chairman of the Supervisory Board, First Deputy Director, Directorate of Investment Banking Operations, Vnesheconombank, Georgy Egorov - Deputy Chairman of the Supervisory Board; Sergey Lykov - Deputy Chairman of the Supervisory Board; Member of the Board- Deputy Chairman, Vnesheconombank, Members of the Supervisory Board: Andrey Arshinov Chairman of the Board of Directors, OJSC INFINITUM Specialized Depository, Ilgiz Valitov - Director, Natural Resources and Construction Directorate, Vnesheconombank, Sergey Vasiliev - Member of the Board, Deputy Chairman, Vnesheconombank, Aleksandr Kernozhitsky Director, Financial Department, Minsk City Executive Committee; Nikolay Kosov First Deputy Chairman, Vnesheconombank, Sergey Kuznetsov - Director of Legal 1 A beneficial owner is a natural person (a body corporate where it is impossible to identify such person) that owns the property of a body corporate or holds an interest (shares) in the authorized share capital of a body corporate in an amount equal to or exceeding 10 per cent thereof, including same via other natural persons and/or bodies corporate, and is in a position to influence decisions to be taken by such body corporate.

Information on the presence or absence at its location of the Bank, its permanent management body, any other body or person that is empowered to act on behalf of the Bank without a Power of Attorney Surname, first name and patronymic (if applicable) of the Chief Executive Officer of the Bank Surname, first name and patronymic (if applicable) of the Chief Accountant of the Bank Department State Corporation, Vnesheconombank, Sergey Noskov - Director of Directorate of Banking Business Support State Corporation Vnesheconombank, Nataliya Rannikh - Head of the Department of Business Administration of Subsidiary Banks, State Corporation, Vnesheconombank, Moscow. Management Board: Chairman of the Management Board - Pavel Kallaour. Deputy Chairmen of the Management Board: Dmitry Kulevatskiy First Deputy Chairman of the Management Board; Oleg Prohortchik - Deputy Chairman of the Management Board; Vladimir Zhourba - Deputy Chairman of the Management Board; Andrei Romanenko - Deputy Chairman of the Management Board; Siarhei Zelianko - Deputy Chairman of the Management Board. Members of the Board: Anatoly Minich - Member of Management Board; Levdansky Dmitry - Member of Management Board, Director of Corporate Business Development Department; Tatyana Polyegoshko - Member of Management Board, Director of Financial and Economic Department. Present Kallaour Pavel Vladimirovich Filipava Liudmila Аlekseevna Is the Bank s CEO a founder of (participant in) other bodies corporate with a stake in the share capital exceeding 25% or an owner of other bodies corporate, including banks? Are founders of (participants in) the Bank holding a stake in the share capital exceeding 25%, owners or beneficial owners, founders of (participants in) other bodies corporate, including banks with a stake in their share capital of over 25%, owners or CEOs of other

bodies corporate? Are beneficial owners politically exposed persons 2 in foreign countries? If yes, please enter their surnames, first names and patronymics (where applicable) Stand-alone units and branches of the Bank and See our site their number http://eng.belveb.by/about/branches/ Representative offices of the Bank and their - number Subsidiaries and associated companies of the See our site Bank and their number Information on the supervisory authority of the country of the Bank s domiciliation (name, location) Does the supervisory authority conduct inspections of the Bank s compliance with AML/CFT regulations? If yes, please state frequency of such inspections Track record, business reputation, banking specialization, information on the size of the market segment controlled and competition, reorganization, changes in activities, etc. Bank s ratings http://eng.belveb.by/about/subsidiares/ National Bank of the 20, Nezavisimosty Ave., 220008 Minsk, The National Bank of the Republic of Belarus reviews AML Policies and Procedures of Bank BelVEB conducts inspections at intervals established by the legislation of the See our site http://eng.belveb.by/about/ See our site http://eng.belveb.by/about/internationalrating/ Name of auditors (self-employed auditor) Ernst & Young Date of last audit 16.03.2012 Is there a possibility of receiving an audit report from the Bank if need arises? Yes No Are there AML/CFT legal and other regulatory acts adopted in the country of the customer s registration? Yes No Has the Bank adopted regulatory documents governing internal control policies and procedures in accordance with national AML/CFT regulations? Are banks in the country of the customer s registration required to comply with AML/CFT regulations? Has the Bank appointed Compliance Officer responsible for the compliance with internal control policies and procedures designed in accordance with national AML/CFT regulations? Yes No 2 Politically exposed person is a natural person who performs or has performed important public functions, members of their families or their close associates (e.g. the term politically exposed person may be applied to heads of state and government, senior judges, senior party functionaries, high-ranking diplomats, senior government administration functionaries and military leaders, heads of organizations engaged in the extraction of natural resources or exercising monopolistic control over the commodity market, senior and influential representatives of religious organizations, etc.)

If yes, please state: His/her surname, first name and patronymic (if applicable) Position title Marina Monastyrnaya Director of Risk - Management Department Telephone, fax +375 17 3096020 e-mail address monastyrnaya@bveb.minsk.by Has the Bank been subject to any sanctions over the last three years on account of breaches of AML/CFT regulations? Please detail remedial measures taken (types of breaches committed) Does the Bank conduct identification of parties to financial transactions? Are potential customers checked for information about their inclusion in the list of individuals and bodies corporate engaged in terrorism? Retention period for customer identification documents Retention period for documents with regard to customer-generated financial transactions subject to special control under national AML/CFT regulations Identification documents retention period in the Bank is five years from the date of terminating contractual relations with a customer Documents relating to the execution and/or performance of financial transactions subject to special control retention period in the Bank is five years from the date of executing such financial transactions Do stand-alone units and branches of the Bank (if any) apply AML/CFT internal control policies and procedures? Has the Bank adopted procedures of documenting suspicious financial transactions and reporting such information to designated financial monitoring agencies? Does the Bank assess risks of customer-generated financial transactions for AML/CFT purposes? Does the Bank take additional measures to exercise control over operations of certain categories of customers and types of transactions that in the Bank s opinion may expose it to a heightened risk of conducting financial transactions with a view to laundering proceeds of crime and financing terrorism in the Bank or via the Bank? Does the Bank collect and analyze information on AML/CFT measures taken by financial institutions from among its customers and their practical application? Does the Bank collect and analyze information on the activities of the Bank s customers? Does the Bank maintain accounts for anonymous holders? Does the Bank maintain accounts with banks that are registered in tax-haven countries and territories and/or do not disclose or provide information when conducting financial

transactions (offshore zones)? Does the Bank maintain correspondent relations with banks that have no physical presence in a country (so-called shell banks )? Does the Bank provide AML/CFT training for its staff?