ANTI MONEY LAUNDERING QUESTIONNAIRE

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1 ANTI MONEY LAUNDERING QUESTIONNAIRE The following questions are intended to facilitate our understanding of the Anti-Money Laundering Polices & Procedures your institution has implemented. (Please circle as appropriate.) CUSTOMER BACKGROUND 1. Name of Customer:. 2. Business Address: Carrera 4 No Santiago de Cali, Colombia 3. Phone(s) Number(s): (57+2) Ext Web site: SWIFT/Telex: OCCICOBC 5. Tax Identification Number: Country and year of licensing: Colombia, sin número. Renovada por Resolución SB No de License Type Domestic International Offshore 8. Principal supervisor entity of the customer: Superintendencia Financiera de Colombia 9. Number of Employees: Number of branches: Principal Officers/Directors of the enterprise (name and title): Name: Efraín Otero Álvarez Title: Presidente Name: Douglas Berrío Zapata Title: Vicepresidente Jurídico Name: Bernardo Escobar Montoya Title: Vicepresidente Financiero Name: Gerardo Silva Castro Title: Vicepresidente Banca Empresarial Name: Efraín Velásquez Vela Title: Vicepresidente Banca Personal Name: Mario Ernesto Calero Buendía Title: Vicepresidente Banca Vehículos Name: Daniel Roberto Gómez Vanegas Title: Vicepresidente de Operaciones Name: Julio César Guzman Victoria Title: Vicepresidente de Crédito Name: Johnny Leyton Fernández Title: Vicepresidente de Riesgo y Cobranza 11. Is the Enterprise rated by any agency (i.e. Moody s, Standard & Poors, Fitch, etc.)? If yes, please provide the name: BRC 1

2 12. Please provide the name of your main correspondent Customer (clearing Customer) in the U.S.A.: Citibank New York 12. Ownership distribution above 5% Grupo Aval Acciones y Valores % Seguros de Vida Alfa % HOME COUNTRY SUPERVISOR 1. Does the Customer s home country supervisor conduct its supervision on a comprehensive basis? 2. Does the customer s home country supervisor conduct regular examinations of the enterprise? 3. If the answer is yes to No. 2, how often are the examinations conducted? Annually 4. Does the customer s home country supervisor conduct its supervision on a consolidated basis? U.S. LEGISLATION 1. Is the enterprise s management aware of the extensive laundering laws in existence in the United Stated including the USA Patriot Act? 2. Is the enterprise s management aware that U.S. laws (and not your home country laws) govern all activities passing through correspondent accounts at a U.S. financial institution? 2

3 3. Is the enterprise s management aware that U.S. laws recognize more than 170 different crimes (not just drugs trafficking) as predicates for the independent crime of money laundering? 4. Is the Customer s management aware of the list published bye the U.S. Office of Financial Assets Control (OFAC) of specially designated narcotraffickers and narcotraffickers kingpins ( OFAC Lists )? 5. Is the Customer s management aware that the U.S. government has classified some countries/jurisdictions as non-cooperating in the fight against international money laundering ( Listed Countries )? HOME COUNTRY LAWS 1. Does the Customer s home country laws recognize money laundering as an independent crime? 2. Does the Customer s home country laws recognize different forms of money laundering, other than that originating from drug trafficking? 3. Does the Customer s home country laws recognize money laundering through non-cash transactions? 4. Does the Customer s home country laws require the Customer to report cash transactions for an amount greater than US $10,000.00? 5. Does the Customer s home country laws require the Customer to report transactions involving unusual or suspicious activity to law enforcement authorities? 6. To what authorities does the Customer report unusual or suspicious activities? Unidad de Información y Análisis Financiero - UIAF 3

4 POLICIES AND PROCEDURES 1. Does the Customer have written policies and procedures designed to prevent, detect and react to money laundering? 2. Are those policies and procedures regularly updated? 3. Is there a person appointed as a Compliance Officer within the Customer responsible for preventing, detecting, and reacting to money laundering? If yes, please provide with his/her name and telephone number: Milton Fabian Villegas Ramos - Telephone: (57) Ext Does the Customer have policies and procedures regarding Know Your Customer to insure that the Customer knows the true identity of its customer? 5. Does the Customer have policies and procedures to verify the identity of its customers? 6. Does the Customer maintain records of account information, and transaction records, for a specific period of time? If the answer to No. 6 is yes, please indicate the recordkeeping period. 10 Years. 7. Has the Customer implemented a customer due diligence program that will allow it to develop a customer profile, including information such as, source of income, origin of income, and normal and expected transactions of the customer? 4

5 MONITORING AND CONTROLS 1. Does the Customer have a system to monitor account and transaction activity to detect money laundering? 2. Does the Customer s monitoring system detect accounts and transactions covered by the OFAC List? 3. Does the Customer perform independent testing to help and insure that anti-money laundering controls are effective? TRAINING 1. Does the Customer have a policy of requiring regular employee training related to money laundering prevention, detection and reaction? COMPLETED BY: Milton Fabian Villegas Ramos TITLE: Compliance Officer DATE: 29/07/2013 Thank you for providing this information, this certification should now be signed by a representative of an independent controls function (such as Legal, Compliance or Audit.) within your institution. 5

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