2023-09-11
Added · Updated
The document establishes a mandatory annual questionnaire for banks operating in the Democratic Republic of Congo to report on their Anti-Money Laundering and Counter-Financing of Terrorism (AML/CFT) frameworks. It requires institutions to provide detailed responses regarding organizational structure, risk mapping, targeted financial sanctions implementation, internal controls, suspicious transaction reporting, and ongoing due diligence procedures. Additionally, it mandates the submission of a monthly statistical report containing specific codes for transaction volumes, client risk profiles, and training metrics.
page 1 ANNEXES - INSTRUCTION 15
page 2 ANNUAL QUESTIONNAIRE
page 3 Institution: Fiscal Year: Start Date: End Date:
ORGANIZATION OF THE AML/CFT FRAMEWORK
| QUESTION NO. | DESCRIPTION | RESPONSES |
|---|---|---|
| 1 | Designation of persons responsible for AML/CFT risk prevention | |
| 2 | Does your bank have procedures covering all its activities? | |
| 3 | Do the provisions in the procedures remind staff members that they are protected from legal prosecution in case of good faith transmission of a STR? | |
| 4 | Has your bank designated a person responsible for preventing money laundering and terrorist financing within its establishment in the DRC? | |
| 5 | In the event that your bank has a subsidiary or branch abroad, have you designated a competent AML/CFT responsible person for the entire group? | |
| 6 | Does a member of management ensure, under the control of the Board of Directors, the coordination of all devices contributing to the mission of preventing ML and TF? | |
| 7 | Do the persons responsible for ensuring the coherence and effectiveness of the AML/CFT prevention device perform other operational tasks? | |
| 8 | Has the executive body been informed of any fact having an impact on the honorability of the AML/CFT prevention manager and the BCC? | |
| 9 | Is it provided that any fact having an impact on the honorability of the AML/CFT prevention manager is communicated to the BCC? | |
| 10 | Is the AML/CFT manager directly attached to General Management? | |
| 11 | Have all staff members received training on the prevention of money laundering and terrorist financing adapted to their functions? | |
| 12 | Has the bank put in place an awareness program for all staff members on the detection of atypical operations? | |
| 13 | Do the procedures provide for the retention for a period of 10 years of documents and records relating to the identity of its clients, including account books, commercial correspondence, and the results of any analysis? |
page 4 Institution: Fiscal Year: Start Date: End Date:
RISK ASSESSMENT
| QUESTION NO. | DESCRIPTION | RESPONSES |
|---|---|---|
| 1 | Has the money laundering and terrorist financing risk map been formalized and documented in writing (on | |
| 2 | is the risk map updated as soon as an event requires it and at least once a year? (indicate in the comment column the date of the last update) | |
| 3 | Has the risk map been approved by the deliberative body? | |
| 4 | To establish the risk map, have the following elements been analyzed | |
| 4a | risks related to your bank's clientele? | |
| 4b | risks related to the products and services offered by your bank? | |
| 4c | risks related to countries or geographic zones at risk? | |
| 4d | risks related to the distribution channels used by your bank? | |
| 4e | risks related to money laundering? | |
| 4f | risks related to terrorist financing? | |
| 4g | risks related to the provision of services and/or the execution of operations that are subject to financial sanctions, embargoes, and/or other restrictive measures? | |
| 5 | Was the risk map established under the responsibility of the AML/CFT manager? | |
| 6 | Is there a control of the relevance of the ML/TF risk map? | |
| 7 | Has your bank carried out a general risk assessment during which the risks to which it is exposed in the field of AML/CFT were detected and evaluated? | |
| 8 | Is there a control of the coherence between the ML/TF risk map and the procedures implemented by the operational lines? | |
| 9 | Does your bank have a client acceptance policy formalized in an internal procedure approved by the deliberative body taking into account the risk map? | |
| 10 | Is the acceptance policy updated at least once a year? (indicate in the comment the date of the last update and the events that led to this last update) |
page 5 Institution: Fiscal Year: Start Date: End Date:
IMPLEMENTATION OF TARGETED FINANCIAL SANCTIONS
| QUESTION NO. | DESCRIPTION | RESPONSES |
|---|---|---|
| 1 | Application of asset freeze measures and prohibition of making funds available | |
| 2 | Is your bank equipped with a device adapted to the characteristics of its activities to ensure that no funds are made available to a person or entity subject to an asset freeze measure? | |
| 2a | Does this device allow collecting current lists of a national or international asset freeze measure | |
| 2b | * a person or entity whose assets are frozen before any business relationship or the execution of an operation with an occasional client? | |
| 2c | * an ongoing business relationship with a person or entity subject to a freeze measure? | |
| 2d | * the funds or other assets held for the account of the client subject to such a measure? | |
| 3 | * the funds or other assets that do not belong to a person or entity subject to an asset freeze measure but are controlled by it? | |
| 3a | Does your bank's device allow systematically controlling beforehand the offer of services if the following persons appear on the national and United Nations Security Council sanctions lists? (indicate in the comments column if your bank uses an automated system (e.g., managed application), manual (e.g., manual comparison of the client file with applicable sanctions lists), or a combination of the two for the controls mentioned above) | |
| 3b | new clients | |
| 3c | their representatives | |
| 4 | the beneficial owners linked to client relationships (beneficial owners of clients, beneficial owners of client representatives, etc.) | |
| 5 | Does your bank's device allow controlling during the execution or receipt of international payment transfers (payments received or made for the benefit of persons or remitted outside the DRC) if the counterparties of its clients appear on the sanctions lists or if the other information attached to the transfer shows correspondences with these lists? | |
| 6 | Does your bank's device allow controlling during the execution or receipt of national transfers (payments within the territory of the DRC) if the counterparties of its clients appear on the sanctions lists or if the other information attached to the transfer shows correspondences with these lists? | |
| 7 | Does your bank's device allow controlling during the granting of means (e.g., in the context of payments, repayments, credits, etc.) if a party present could have been sanctioned? | |
| 8 | Are the instructions for handling alerts mentioned in the procedures that are disseminated to staff members? | |
| 9 | Does your bank have procedures clarifying how to act within your establishment when it is found and established that one of the clients (one of its relationships) actually appears on the sanctions lists (effective match)? (e.g., procedure for freezing funds and/or assets, intervention of the appropriate hierarchical level, reporting to the Minister of Finance, etc.) | |
| 10 | Do the procedures mention how the staff members of your bank must give eventual correspondences between the data of clients and their relationships (representatives, beneficial owners, and/or counterparties) and the sanctions lists to decide on the basis of this examination whether it is a false or effective correspondence with the sanctions lists? | |
| 11 | Is the obligation to inform the National Financial Intelligence Unit without delay of the existence of funds or other assets belonging to persons or entities subject to a freeze decision mentioned in the bank's procedures? | |
| 12 | Have controls (internal control or audit) been carried out to ensure the implementation of their entry into force of the measures freezing funds or other assets? (in the comments column, specify the date of the last control carried out on the asset freeze device) |
page 6 Institution: Fiscal Year: Start Date: End Date:
INTERNAL CONTROL
| QUESTION NO. | DESCRIPTION | RESPONSES |
|---|---|---|
| 1 | Organization of the internal control device | |
| 1a | Has your bank put in place internal control procedures comprising the points below | |
| 1b | identification | |
| 1c | implementation of constant vigilance measures | |
| 1d | implementation of simplified vigilance measures | |
| 1e | implementation of enhanced vigilance measures | |
| 1f | detection of unusual or suspicious operations | |
| 1g | implementation of enhanced examination procedures | |
| 1h | retention of documents | |
| 1i | obligation to report suspicion to the National Financial Intelligence Unit | |
| 2 | Does permanent control verify compliance | |
| 2a | with the obligation to report suspicion to the National Financial Intelligence Unit | |
| 2b | with the obligation to report suspicion to the National Financial Intelligence Unit | |
| 2c | with the handling of alerts | |
| 3 | with declarative diligences | |
| 3a | Does permanent control verify compliance | |
| 3b | (specify the date of the last control on the AML/CFT device and communicate the report) | |
| 3c | collection of identification elements in the client file | |
| 3d | updating of client files | |
| 3e | modalities for transmitting declarative declarations | |
| 3f | updating of the ML and TF risk map | |
| 3g | coherence between the risk map and procedures related to AML/CFT | |
| 3h | effectiveness of the device for detecting and analyzing atypical operations | |
| 3i | effectiveness and relevance of the controls implemented by permanent control in matters of AML/CFT |
page 7 Institution: Fiscal Year: Start Date: End Date:
SUSPICIOUS TRANSACTION REPORTING AND CENAREF RESPONSIBLE
| QUESTION NO. | DESCRIPTION | RESPONSES |
|---|---|---|
| 1 | Do the procedures provide that a suspicious transaction report must be made as soon as the account manager suspects or has good reasons to suspect that the sums withdrawn without the titles, the operation, or the attempted operation are related to money laundering or terrorist financing? | |
| 2 | Do the procedures provide that the account manager must refrain from executing any operation of cash deposit or by electronic money carrying a unitary or higher amount of 10,000 dollars | |
| 3 | (indicate in comments if the situation is different) | |
| 4 | Do the declarative declaration procedures specify the duty to provide on the suspicious transaction report | |
| 4a | analysis elements? | |
| 4b | * When the transmission of the report to CENAREF is carried out prior to the execution of the operation in particular | |
| 4c | * Any information allowing to declare and demonstrate the suspicions? | |
| 5 | Do the procedures provide to give the order not to perform identification diligences | |
| 6 | * Operations carried out with a fiduciary fund or any other wealth management instrument being the identity of the beneficiaries or the beneficiaries is not known? | |
| 6b | * Operations that have been subject to an enhanced examination prescribed in article 46 | |
| 6c | CENAREF CORRESPONDENT | |
| 7 | Are the names of the CENAREF correspondents communicated to CENAREF as soon as they are designated? (in case of negative answer mention in the comments column the responsible person designated for this task and the organization of the device in the absence of identity and name) | |
| 8 | Do the identity and contact details of the correspondents appear in the anti-money laundering procedures of the establishment? |
page 8 Institution: Fiscal Year: Start Date: End Date:
CONSTANT VIGILANCE OBLIGATION FOR ML/TF RISKS
| QUESTION NO. | DESCRIPTION | RESPONSES |
|---|---|---|
| 1 | Client identification | |
| 2 | Has your bank put in place a system allowing the detection of deposits and cash withdrawals for an amount greater than or equal to the equivalent in CDF of USD 10,000? | |
| 3 | Do the procedures provide to enter into a business relationship or assist the client in the preparation or realization of an operation your bank proceeds | |
| 4 | to the identification of the client and, if applicable, the beneficial owner of the business relationship | |
| 5 | to the collection of information on the professional, economic, and financial situation of clients based on the risks presented in the business relationship | |
| 6 | What are the documents accepted for the identification requirements defined in a procedure | |
| 7 | voter card | |
| 8 | refugee card issued by the National Commission for Refugees | |
| 9 | national identity card | |
| 10 | passport | |
| 11 | student card attested by a university establishment recognized by the State that issued | |
| 12 | army or police card | |
| 13 | certificate from the Village Chief or Neighborhood Chief | |
| 14 | list of beneficiaries of social programs duly identified by the competent authorities or the Social Fund of the DRC | |
| 15 | birth certificate | |
| 16 | Are the information related to client identification updated as needed to maintain complete knowledge of clients? (If yes, give in the comment the date of the last update of the questionnaire and explain the modifications made) | |
| 17 | Do the device or procedures of your bank provide to establish a risk profile of the clientele according to the nature and importance of the money laundering and terrorist financing risk? (Specify the factors used to perform this classification) | |
| 18 | Does the procedure provide the situations where the account manager must submit the admission of a new client to the opinion of his hierarchical superior? | |
| 19 | In the hypothesis where the verification of the client and, if applicable, the beneficial owner, the collection of information on the object and nature of the business relationship proves impossible, do the procedures provide that your bank abstains from establishing the business relationship? (If yes, indicate in the comments the references of this internal procedure) | |
| 20 | Does the procedure impose the vigilance measures to be implemented in the situation of an occasional client? | |
| 21 | Has your bank been equipped with procedures of a device allowing to determine if the client or a beneficial owner of the client is a Politically Exposed Person | |
| 22 | upon entering into a business relationship or during the business relationship during the business relationship? | |
| 23 | Question No. | |
| 24 | Operation surveillance | |
| 25 | Do your bank's procedures require enhanced surveillance for operations carried out for the account of a certain category of clients (natural or legal persons, notably notaries, lawyers, accountants, companies that carry out as a habitual profession the intermediation and assistance in matters of wealth management? | |
| 26 | Do your bank's procedures require the implementation | |
| 27 | of enhanced vigilance regarding operations carried out by persons whose mail is domiciled with a third party in a post office box at the counters of a credit establishment or who change address frequently? (If yes, give in the comment the references of this procedure) | |
| 28 | Enhanced vigilance procedures for higher ML/TF risks other than those provided by regulation? | |
| 29 | Vigilance measures completed for lower ML/TF risks other than those provided by regulation? | |
| 30 | Are the enhanced vigilance measures referred to in question 25 detailed in the procedure? | |
| 31 | Question No. | |
| 32 | Has your bank been equipped with an automated system for detecting atypical operations of the clientele? (If yes, explain in the comment the name and nature of the device put in place) | |
| 33 | Do the internal instructions of your bank provide that the opening of anonymous accounts or accounts with fictitious names is prohibited? | |
| 34 | Do your bank's procedures provide that complementary vigilance measures are applied to clients in the cases below | |
| 35 | the client or his legal representative is not physically present for the purpose of identification? | |
| 36 | the client is a politically exposed person? | |
| 37 | the product or operation favors the anonymity of the latter? | |
| 38 | the operations are carried out in favor of natural or legal persons domiciled, registered, or established in tax havens or States found on the grey or black list of the FATF? | |
| 39 | Question No. | |
| 40 | Do your bank's procedures provide for the systematic dissemination of the lists to clients in the previous question to all concerned staff? | |
| 41 | Indicate if your bank's procedures require the complementary measures required in question 8 | |
| 42 | Has your bank put in place a procedure providing for an enhanced examination of any particularly complex operation, i.e., an operation presenting the characteristics below | |
| 43 | an unusually high amount | |
| 44 | an operation that does not appear to have an economic justification | |
| 45 | an operation that does not appear to have a lawful object | |
| 46 | Do the internal instructions of your bank provide to record in the framework of an enhanced examination the justifications of the analysis that led to the closure of the examination? | |
| 47 | Question No. | |
| 48 | Vigilance measures in case of banking correspondence | |
| 49 | Prior to the conclusion of a service offer convention for banking correspondence, check collection, or discounting of checks or to establish a business relationship for the distribution of financial instruments, does your bank proceed in its AML/CFT file | |
| 50 | collect from the corresponding establishment sufficient information to know the nature of its activities and appreciate the reputation and quality of the surveillance to which the reports on governance, internal control, the AML/CFT device, the auditors' reports, etc. are subject? | |
| 51 | Verify if the establishment has been subject to sanctions notified by its supervisory Authority in case of advancements in its AML/CFT file? | |
| 52 | provide in the banking correspondence convention or distribution of financial instruments the modalities for the transmission without delay of information on clients and their operations between corresponding establishments? |
page 9 MONTHLY AML/CFT REPORTING
page 10 Institution: Fiscal Year: Start Date: End Date:
SUPERVISION DEVICE FOR THE FIGHT AGAINST MONEY LAUNDERING AND TERRORIST FINANCING
| CODE | DESCRIPTION | VALUE |
|---|---|---|
| LAB1 | Constant vigilance | |
| LAB2 | Number of operations not appearing to have an economic justification (this month) | |
| LAB3 | Number of operations not appearing to have a lawful object (this month) | |
| LAB4 | Number of unusual or suspicious operations (this month) | |
| LAB5 | Number of cash operations greater than or equal to USD 10,000 (this month) | |
| LAB6 | Number of cash operations greater than USD 9,000 and less than USD 10,000 (this month) | |
| LAB7 | Number of clients with a high risk profile | |
| LAB8 | Number of clients with a medium risk profile | |
| LAB9 | Number of clients with a low risk profile | |
| LAB10 | Amount of operations of high-risk clients (this month) | |
| LAB11 | Amount of operations of medium-risk clients (this month) | |
| LAB12 | Amount of operations of low-risk clients (this month) | |
| LAB13 | Total amount of client operations (this month) | |
| LAB14 | Amount of operations with PEPs | |
| LAB15 | Number of PEPs | |
| LAB16 | Suspicious transaction report | |
| LAB17 | Number of suspicions reported to CENAREF (this month) | |
| LAB18 | Organization of the AML/CFT device | |
| LAB19 | Number of agents who have undergone AML/CFT training (this month) | |
| LAB20 | Total number of agents | |
| LAB21 | Number of accounts | |
| LAB22 | Number of non-resident accounts | |
| LAB23 | Number of operations with foreign entities (this month) | |
| LAB24 | Amount of banknote imports (this month) |
page 11 Institution: Fiscal Year: Start Date: End Date:
LOCATION
| CODE | LIBELLE | VALEUR |
|---|---|---|
| LAB1 | Presence of entities belonging to the group of the Congolese entity (e.g.: sister company or parent company) in one of the following countries | |
| LAB2 | a) Republic of Congo, Rwanda, South Sudan, Tanzania, Angola, Central African Republic, Uganda, Zambia, Burundi? | |
| LAB3 | b) grey list? | |
| LAB4 | c) black list? | |
| LAB5 | d) offshore centers or territories? | |
| LAB6 | e) other countries | |
| LAB7 | What is the distribution of the client portfolio by location: | |
| LAB8 | a) total number of clients in DRC - Excluding those who opened their accounts in an agency located in the following provinces: North Kivu, South Kivu, Ituri, Maniema, Haut-Uele, Bas-Uele (this month) | |
| LAB9 | b) total number of clients in DRC who opened their account located in the following provinces: North Kivu (this month) | |
| LAB10 | bii) total number of clients in DRC who opened their account located in the following provinces: South Kivu (this month) | |
| LAB11 | biii) total number of clients in DRC who opened their account located in the following provinces: Ituri (this month) | |
| LAB12 | biv) total number of clients in DRC who opened their account located in the following provinces: Maniema (this month) | |
| LAB13 | bv) total number of clients in DRC who opened their account located in the following provinces: Haut-Uele (this month) | |
| LAB14 | bvi) total number of clients in DRC who opened their account located in the following provinces: Bas-Uele (this month) | |
| LAB15 | c) number of clients in Congo, Rwanda, South Sudan, Tanzania, Angola, Central African Republic, Uganda, Zambia and Burundi? | |
| LAB16 | d) number of clients in a country on the FATF grey list? | |
| LAB17 | e) number of clients in a country on the FATF black list? | |
| LAB18 | f) number of clients in another country | |
| LAB19 | Among incoming transfer operations, how many were executed from an account opened in one of the following countries: | |
| LAB20 | a) Congo | |
| LAB21 | b) Rwanda | |
| LAB22 | c) South Sudan | |
| LAB23 | d) Tanzania | |
| LAB24 | e) Sudan | |
| LAB25 | f) grey list? | |
| LAB26 | g) black list? | |
| LAB27 | h) other countries? |
page 12 Institution: Accounting Year: Start Date: End Date:
CLIENT PORTFOLIO
| CODE | LIBELLE | VALEUR |
|---|---|---|
| LAB1 | Indicate the total number of persons or entities who during the year, although meeting the criteria defined by the client acceptance policy, were refused for reasons related to AML/CFT. | |
| LAB2 | What is the number of PEPs | |
| LAB3 | What is the number of non-resident clients | |
| LAB4 | What is the total number of clients by legal status | |
| LAB5 | a) number of natural persons? | |
| LAB6 | b) number of legal entities? | |
| LAB7 | c) number of trusts? | |
| LAB8 | d) number of legal constructors? | |
| LAB9 | e) number of associations? | |
| LAB10 | Provide the breakdown of your client portfolio by the risk categories retained by your organization | |
| LAB11 | a) number of high-risk clients? | |
| LAB12 | b) number of medium-risk clients? | |
| LAB13 | c) number of low-risk clients? |
page 13 Institution: Accounting Year: Start Date: End Date:
PRODUCT, SERVICE AND OPERATIONS
| CODE | LIBELLE | VALEUR |
|---|---|---|
| LAB1 | Total number of operations | |
| LAB2 | Total number of bank guarantees from a person established in a listed country or a tax haven | |
| LAB3 | Total number of bank guarantees | |
| LAB4 | Total number of credits | |
| LAB5 | Total number of consumer credits | |
| LAB6 | Total number of credit guaranteed by a DAT | |
| LAB7 | Number of cash operations (Debit) > 10k USD | |
| LAB8 | Total number of cash operations (Debit) | |
| LAB9 | Number of cash operations (Credit) > 10k USD | |
| LAB10 | Total number of cash operations (Credit) | |
| LAB11 | Number of international transfers | |
| LAB12 | Total amount of operations carried out by exchange offices | |
| LAB13 | Number of operations carried out by exchange offices | |
| LAB14 | Number of national transfers | |
| LAB15 | Provide in amount the distribution of operations executed during the month according to the different client risk categories defined by your organization. (In CDF Unit) | |
| LAB16 | a) low risk | |
| LAB17 | b) medium risk | |
| LAB18 | c) high risk |
page 14 Institution: Accounting Year: Start Date: End Date:
DISTRIBUTION CHANNELS
| CODE | LIBELLE | VALEUR |
|---|---|---|
| LAB1 | Number of operations carried out by Mobile banking | |
| LAB2 | Number of operations carried out by internet banking | |
| LAB3 | Number of operations carried out via banking agents | |
| LAB4 | Total amount of operations carried out by Mobile banking | |
| LAB5 | Total amount of operations carried out by internet banking | |
| LAB6 | Total amount of operations carried out via banking agents | |
| LAB7 | Number of outgoing international electronic transfers - to - listed countries | |
| LAB8 | Number of incoming electronic transfers - from - listed countries | |
| LAB9 | Total number of transfer operations executed by financial messaging services backed by a banking institution (debit) | |
| LAB10 | Total number of transfer operations executed by financial messaging services backed by a banking institution (credit) | |
| LAB11 | Total amount of transfer operations executed by financial messaging services backed by a banking institution (debit) | |
| LAB12 | Total amount of transfer operations executed by financial messaging services backed by a banking institution (credit) |
page 15 ANNEX DSSP
page 16 Institution: Accounting Year: Start Date: End Date:
ANTI-MONEY LAUNDERING AND COUNTER-TERRORIST FINANCING FRAMEWORK
| LIBELLE | VALEUR |
|---|---|
| 1. Constant vigilance | |
| Number of operations that do not appear to have an economic justification | |
| Number of operations that do not appear to have a lawful object | |
| Number of unusual or suspicious operations | |
| Number of clients with a high risk profile | |
| Number of clients with a medium risk profile | |
| Number of clients with a low risk profile | |
| Amount of operations for high-risk clients | |
| Amount of operations for medium-risk clients | |
| Total amount of client operations | |
| Amount of operations with PEPs | |
| Number of PEPs | |
| 2. Suspicious transaction reporting | |
| Number of suspicions reported to CENAREF | |
| Value of transactions that were the subject of suspicions | |
| Type of payment instruments that were the subject of suspicions | |
| 3. Fraud monitoring on payment methods | |
| Fraud on the issuance of electronic money | |
| Vishing/smishing fraud » | |
| Advance fraud | |
| Fraudulent payment | |
| False operation | |
| Operation splitting | |
| Fake account | |
| Identity theft | |
| Fraudulent deposit on an ATM | |
| Unauthorized access to an electronic money account | |
| Number of documentary frauds at account opening (counterfeit or falsified documents) | |
| Number of identity frauds at account opening (authentic stolen identity document) | |
| Number of documentary frauds during the business relationship | |
| Value of documentary frauds at account opening | |
| Value of identity frauds at account opening | |
| Value of documentary frauds during the business relationship | |
| Other cases | |
| 4. Merchant | |
| Number of merchants registered during the month | |
| Number of active merchants (having registered at least 1 transaction in the last 90 days) | |
| Type of services offered by merchants | |
| 5. Registered agents/distributors | |
| Total number of agents | |
| Transaction volume profile by agent/distributor type | |
| Transaction value profile by agent/distributor type | |
| 6. Active agent/distributors | |
| Total number of active agents | |
| Total number of active distributors | |
| 7. Aggregators | |
| List of aggregators under contractual link | |
| Type of services offered by aggregators under contractual link | |
| 8. Correspondents | |
| Number of foreign correspondent banks | |
| Number of local correspondent banks | |
| Number of correspondents who have been the subject of an investigation related to AML/CFT |
page 17 Institution: Accounting Year: Start Date: End Date:
ANNUAL EVALUATION OF THE ANTI-MONEY LAUNDERING AND COUNTER-TERRORIST FINANCING PLATFORM
| REF | LIBELLE | VALEUR |
|---|---|---|
| 1. | General Information (Answer YES or NO) | |
| Do you have an automated tool for detecting atypical or suspicious operations operational? | ||
| What is the name of the implemented AML/CFT platform? | ||
| Who is the platform provider. | ||
| 2. | Integrated watchlist in your automated AML/CFT system (Answer YES or NO) | |
| United Kingdom List | ||
| Office of Foreign Assets Control (OFAC) List | ||
| European Union List | ||
| Bureau of Foreign Assets Control List | ||
| Bank of Japan List | ||
| PEP List (local and foreign) | ||
| Local black list | ||
| Other black list | ||
| Automated loading of black lists | ||
| Manual loading of black lists | ||
| 3. | Warning Methods (Answer YES or NO) | |
| Network address warning | ||
| Country warning | ||
| Keyword warning | ||
| Limits | ||
| Exchange controls |
page 18 Institution: Accounting Year: Start Date: End Date:
CUSTOMER DUE DILIGENCE
| LIBELLE | VALEUR | |
|---|---|---|
| 1. | Indicate the total number of persons or entities who during the year, although meeting the criteria defined by the client acceptance policy of your organization, were refused for reasons related to AML/CFT. | |
| What is the number of PEPs | ||
| What is the number of non-resident clients | ||
| 2. | What is the total number of clients by legal status | |
| number of payment instruments issued in the name of legal entities? | ||
| number of payment instruments issued to non-profit associations? | ||
| 3. | Provide the breakdown of your client portfolio by the risk categories retained by your organization | |
| Number of transactions carried out by non-residents | ||
| number of high-risk clients? | ||
| number of medium-risk clients? | ||
| number of low-risk clients? | ||
| Number of accounts registered related to AML/CFT | ||
| Number of registered legal entity accounts related to AML/CFT | ||
| Number of registered PEP accounts | ||
| Number of PEPs who are national beneficial owners | ||
| Number of PEPs who are foreign beneficial owners | ||
| Number of "full KYC" accounts | ||
| Number of "Minimum KYC" accounts | ||
| Number of clients holding more than one registered account | ||
| Number of clients exceeding the regulatory transaction ceiling after BCC authorization | ||
| 4. | Identification of persons acting on behalf of others | |
| Number of persons identified acting for third parties | ||
| Existence of authorizations to represent a third party (answer Yes or No) | ||
| Number of beneficial owners identified | ||
| Number of clients whose documents, data or information obtained in the exercise of due diligence remain up to date and relevant. | ||
| Number of occasional clients | ||
| Number of clients holding an ICU issued by the BCC | ||
| 5. | Registered account | |
| Number of registered accounts concerned by AML/CFT operations | ||
| Number of registered legal entity accounts concerned by AML/CFT operations | ||
| Number of registered PEP accounts | ||
| Number of PEP accounts authorized by the Senior Management of the establishment | ||
| Number of PEPs who are national beneficial owners | ||
| Number of PEPs who are foreign beneficial owners | ||
| Number of "full KYC" accounts | ||
| Number of "Minimum KYC" accounts | ||
| Number of clients exceeding the regulatory transaction ceiling after BCC authorization | ||
| 6. | Total of active accounts | |
| Number of active individual accounts | ||
| Number of active legal entity accounts |
page 19 Institution: Accounting Year: Start Date: End Date:
MONTHLY SURVEILLANCE OF PAYMENT INSTRUMENTS AND ACQUISITION CHANNELS IN THE FRAMEWORK OF AML/CFT
| REF | LIBELLE | VALEUR |
|---|---|---|
| i | Vigilance on payment operations | |
| 1. | Transfers | |
| Number of intrabank transfers not processed due to insufficient information from the order giver | ||
| Value of intrabank transfers not processed due to insufficient information from the order giver | ||
| Volume of domestic interbank transfers including inaccurate information | ||
| Volume of domestic interbank transfers with inaccurate information | ||
| Volume of international interbank transfers with inaccurate information | ||
| Volume of international interbank transactions with inaccurate information | ||
| Volume of domestic interbank transactions processed at correspondents with inaccurate information | ||
| Value of domestic interbank transactions processed at correspondents including inaccurate information | ||
| Volume of occasional transfers greater than USD 10,000 | ||
| Value of occasional transfers greater than USD 10,000 | ||
| Number of transfers in favor of exchange offices | ||
| Value of transfers in favor of exchange offices | ||
| 2. | Electronic money | |
| Number of electronic money issuances by the bank managing the Escrow Account | ||
| Value of electronic money issuances by the bank managing the Escrow Account | ||
| Outstanding of client electronic money | ||
| Outstanding of Agent electronic money | ||
| Number of clients holding more than one electronic money account | ||
| Ceiling of the value of electronic money stored on an account | ||
| Ceiling of the value of electronic money on an account | ||
| 3. | Prepaid card | |
| Number of cards issued | ||
| Value of cards issued | ||
| Number of clients having more than 2 cards individually | ||
| Value stored for clients having more than 2 cards | ||
| Daily payment limit | ||
| Monthly payment limit | ||
| 4. | Money transfer | |
| Total number of incoming transfers | ||
| Total value of incoming transfers | ||
| Total number of outgoing transfers | ||
| Total value of outgoing transfers | ||
| Daily number of outgoing international electronic transfers - to - listed countries | ||
| Daily number of incoming international electronic transfers - from - listed countries | ||
| Daily number of outgoing transfer operations via financial messaging services backed by a banking institution | ||
| Daily number of incoming transfer operations via financial messaging services backed by a banking institution | ||
| Total value of outgoing transfer operations via financial messaging services backed by a banking institution | ||
| Total value of incoming transfer operations via financial messaging services backed by a banking institution | ||
| Number of daily transactions by foreign correspondent | ||
| Value of daily transactions by local correspondent | ||
| ii | Vigilance on Distribution Channels | |
| Number of operations carried out by Mobile banking | ||
| Number of operations carried out by internet banking | ||
| Number of operations carried out via banking agents | ||
| Number of ATM deposit operations | ||
| Number of transactions processed by Aggregator | ||
| Number of web payments | ||
| Value of operations carried out by Mobile banking | ||
| Value of operations carried out by internet banking | ||
| Value of operations carried out via banking agents | ||
| Value of ATM deposit operations | ||
| Value of transactions processed by Aggregator | ||
| Value of web payments |
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