DUE DILIGENCE FORM FOR CREDIT UNIONS RELATING TO THEIR ANTI-MONEY LAUNDERING SYSTEMS AND CAPABILITIES

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1 Credit Union Anti-Money Laundering (AML) Questionnaire This questionnaire is intended to form a part of the Credit Union Fund Management Company Ltd. (CUFMC) Client Due Diligence process and should be completed by a Management Officer who is responsible for the credit union s Anti-Money Laundering (AML) program. Any questions or concerns regarding the form should be directed to the CUFMC. Name of Credit Union Anti Money Laundering Policies and Procedures 1. Does the Credit Union have an AML Compliance Program? 2. If the answer to question 1 is yes: a. Does the AML Compliance Program in general require the approval of the Board of Directors? b. Is there an AML Policy documenting the processes and procedures to be followed to prevent, detect and report transactions that may be connected to money laundering? c. Does the Board of Directors or a committee thereof, review the effectiveness of the AML Program at least annually? d. Does the AML policy apply to all branches and all subsidiaries? e. Does your policy contain stipulations on relationships with politically exposed persons consistent with industry best practices? f. Do your AML or Operational policies contain provisions on the retention of transaction and customer records? 1

2 Compliance Officer and Audit 3. Does the AML Program require the appointment of a Compliance Officer who is responsible for coordinating and overseeing the AML Program on day-to-day basis? 4. Is the Compliance Officer approved by the Board of Directors or a committee thereof? Customer Due Diligence 5. Have the Know Your Customer (KYC) and Customer Due Diligence (CDD) measures required in the law which ensure the identification of its clients and their source of funds? 6. Is a separate record established for each customer at the time of opening an account or starting a business relationship? 7. Are steps taken to understand the expected transaction profile of each customer based on a risk assessment of the customer? 8. Is an appropriate level of enhanced due diligence required for customers deemed to be high risk? 9. Are steps taken to understand the intended normal purpose and nature of customer transactions and business relationships? 10. Are there policies and procedures requiring the verification of customer identities by an independent means? Transaction Monitoring & Reporting 11. If the answer to 10 (above) is yes, has the CU implemented policies and procedure to ensure the identification and reporting of transactions that are required to be reported? 2

3 12. Are there policies and procedures for the identification of suspicious transactions? Yes No 13. Is there a monitoring program aimed at identifying suspicious activity including the monitoring of wire transfers, and cambio transactions? Designated Individuals and Countries 14. Is there a system to screen all customers against lists of high-risk individuals, groups, organizations and states issued by Government or international agencies? 15. Are there procedures in place to ensure that transactions are not conducted with high-risk individuals? Staff and Agents 16. Are there legal requirements to provide regular AML training to all employees in the credit union? 17. Is AML training that includes the identification and reporting of transactions and the recognition of different forms of money laundering provided to all employees on an annual basis? 18. Are there policies and procedures requiring checks into the financial, employment & criminal history (if any) of all the CU s new hires and existing employees? 19. Are there policies and procedures aimed at ensuring high standards of employee integrity including an employee code of ethics? 20. Does the credit union employ agents to carry out some of its functions? 21. If the answer to 20 (above) is yes, are all agents provided with AML training equivalent to the training provided to staff, including training on detecting different types of Money Laundering and reporting responsibilities? 3

4 Record Retention 22. Does the credit union have a system for record retention in accordance with the AML? 23. Are records maintained for all AML training sessions including attendance records and relevant training materials? 24. Are there policies and procedures in place for the communication of changes in AML related laws, policies and procedures to all employees? Regulatory Sanctions 25. Is the credit union subject to the supervision of an External Regulatory Body (e.g. apart from The Registrar of Co-ops, FSC, BOJ)? 26. If the answer to question 25 is yes: Please identify the regulator: a. Is the CU currently subject to any regulatory or criminal actions, sanctions or investigations resulting from violations of laws relating to money laundering and terrorist financing? b. Has the CU been the subject of any regulatory or criminal actions or sanctions in the last 5 years resulting from violations of laws relating to money laundering and terrorist financing? c. If the answer to questions a or b is yes, please give details below: 4

5 d. If the answers to questions a or b (above) is yes, please give details of remedial actions taken below. On behalf of the forenamed CU the undersigned representative who is responsible for the financial Institution s Anti-Money Laundering Compliance Program hereby warrants that the responses provided herein are true. The credit union also understands that CUFMC may request additional information as part of its due diligence process and hereby undertakes to immediately advise CUFMC of any change in facts or circumstances that would affect any of the representations made on this form. Print Name Date Signature 5