Anti-Money Laundering Questionnaire I. General AML

CIMB GROUP HOLDINGS BERHAD (706803-D)
Location: Level 13, Menara CIMB, Jalan Stesen Sentral 2, Kuala Lumpur Sentral, 50470 Kuala
Lumpur, Malaysia
CIMB Group Holdings Berhad is the Financial Holding Company of the Financial Group, as
defined and regulated under Malaysia’s Financial Services Act 2013, Islamic Financial Services
Act 2013 and the Anti-Money Laundering and Anti-Terrorism Financing Act 2001.
CIMB Group Holdings Berhad is listed on Bursa Malaysia Securities (stock code: 1023)
Anti-Money Laundering Questionnaire
The Attached Questionaire provides an overview of the Group’s policies, practices and preventive efforts to combat
money laundering and the financing of terrorism. Where there is a conflict between the Group’’s policies and a foreign
reporting institution’s regulatory requirements, the more stringent of the stringent requirement shall prevail.
I. General AML Policies, Practices and Procedures:
1. Is the AML compliance program approved by the FI’s board or a
senior committee?
2. Does the FI have a legal and regulatory compliance program that
includes a designated officer that is responsible for coordinating and
overseeing the AML framework?
3. Has the FI developed written policies documenting the processes
that they have in place to prevent, detect and report suspicious
transactions?
4. In addition to inspections by the government supervisors/regulators,
does the FI client have an internal audit function or other
independent third party that assesses AML policies and practices on
a regular basis?
5. Does the FI have a policy prohibiting accounts/relationships with
shell banks? (A shell bank is defined as a bank incorporated in a
jurisdiction in which it has no physical presence and which is
unaffiliated with a regulated financial group.)
6. Does the FI have policies to reasonably ensure that they will not
conduct transactions with or on behalf of shell banks through any of
its accounts or products?
7. Does the FI have policies covering relationships with Politically
Exposed Persons (PEP’s), their family and close associates?
8. Does the FI have record retention procedures that comply with
applicable law?
9. Are the FI’s AML policies and practices being applied to all branches
and subsidiaries of the FI both in the home country and in locations
outside of that jurisdiction?
II. Risk Assessment
10. Does the FI have a risk-based assessment of its customer base and
their transactions?
11. Does the FI determine the appropriate level of enhanced due
diligence necessary for those categories of customers and
transactions that the FI has reason to believe pose a heightened risk
of illicit activities at or through the FI?
Yes
Y
Y
Y
Y
Y
Y
Y
Y
Y
Yes
Y
Y
Note 1: For ease of reference, the CIMB Group’s AML/CFT policies, efforts and countermeasures have been
categorized based on the The Wolfsberg Group financial services industry principles and questionnaire for
Know Your Customer, Anti-Money Laundering and Counter Terrorist Financing policies. All rights in relation to
the form and structure of the questions remain with the Group.
Page 1 of 6
No
No
III. Know Your Customer, Due Diligence and Enhanced Due Diligence
12. Has the FI implemented processes for the identification of those
customers on whose behalf it maintains or operates accounts or
conducts transactions?
13. Does the FI have a requirement to collect information regarding its
customers’ business activities?
14. Does the FI assess its FI customers’ AML policies or practices?
15. Does the FI have a process to review and, where appropriate,
update customer information relating to high risk client information?
16. Does the FI have procedures to establish a record for each new
customer noting their respective identification documents and ‘Know
Your Customer’ information?
17. Does the FI complete a risk-based assessment to understand the
normal and expected transactions of its customers?
IV. Reportable Transactions and Prevention and Detection of
Transactions with Illegally Obtained Funds
18. Does the FI have policies or practices for the identification and
reporting of transactions that are required to be reported to the
authorities?
19. Where cash transaction reporting is mandatory, does the FI have
procedures to identify transactions structured to avoid such
obligations?
20. Does the FI screen customers and transactions against lists of
persons, entities or countries issued by government/competent
authorities?
21. Does the FI have policies to reasonably ensure that it only operates
with correspondent banks that possess licenses to operate in their
countries of origin?
22. Does the FI adhere to the Wolfsberg Transparency Principles and
the appropriate usage of the SWIFT MT 202/202COV and MT
205/205COV message formats?
V. Transaction Monitoring
23. Does the FI have a monitoring program for unusual and potentially
suspicious activity that covers funds transfers and monetary
instruments such as travelers checks, money orders, etc?
VI. AML Training
24. Does the FI provide AML training to relevant employees that
includes:
Identification and reporting of transactions that must be reported to
government authorities.
Examples of different forms of money laundering involving the FI’s
products and services.
Internal policies to prevent money laundering.
25. Does the FI retain records of its training sessions including
attendance records and relevant training materials used?
26. Does the FI communicate new AML related laws or changes to
existing AML related policies or practices to relevant employees?
27. Does the FI employ third parties to carry out some of the functions
of the FI?
28. If the answer to question 26 is yes, does the FI provide AML training
to relevant third parties that includes:
Identification and reporting of transactions that must be reported to
government authorities.
Examples of different forms of moneyPage
laundering
involving the FI’s
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products and services.
Internal policies to prevent money laundering.
Yes
Y
No
Y
Y
Y
Y
Y
Yes
No
Y
Y
Y
Y
Y
Yes
Y
No
Yes
Y
No
Y
Y
Y
Y
Additional information:
1. Sanctions
As a responsible member of the international financial community, CIMB Group’s policies
require its reporting institutions (RIs) to comply with:
1. International Sanctions by United Nations;
2. Sanctions and orders issued by the Government of Malaysia’s regulators and law
enforcement agencies (LEAs) or the RI’s home country regulator;
3. Sanctions by other regulators or LEAs recognised by Malaysia; and
4. Restrictions on international transactions with:
• Other entities from countries that have been sanctioned by the US-OFAC, the
UK Treasury, the European Union (“EU”), particularly when dealing in
international currencies (e.g. USD, EUR, GBP); or
• Agent/correspondent banks that adopt their own national or international
sanctions.
In relation to the High Risk countries, where the Financial Action Task Force (“FATF”)
has called for counter measures to be applied, CIMB Group entities will refrain from
entering into any business relationship, transaction (whether directly or indirectly) or
provide any financial services to designated persons or entities (“designated persons”)
including the governments, its agencies financial institutions and government linked
companies (GLCs) or persons or entities known to be controlled by such entities.
This would include non-residents, non-resident companies and non-resident controlled
companies, where ambiguity or opacity of beneficial ownership, may give rise to control
by such entities. Restriction on relationships are deemed to include the facilitation,
arrangement, facilitation of the entering into or continued participation in any transaction
or relationship, including but not limited to remittance services, correspondent banking,
agency or partnering agreements.
2. Correspondent Banking Accounts and Relationships:
Banking Reporting Institutions within CIMB Group do not permit third parties to directly
access nor use correspondent accounts to transact on behalf of others.
3. Contact Information:
For more information related to AML/CFT, sanctions or other information, please contact
the Group AML Office at:
General Line
Facsimile Line (General/AML)
: +603 2261 8888
: +603 2261 0251 / +603 2261 0249
Group AML Office Representatives:
Subramaniam Vayaravasamy, Vice President ([email protected])
Andy Yew Choo Ying ,
Vice President ([email protected])
Sugantha Muthukrishnan, Asst. Vice President ([email protected])
For specific entities within the Group, please contact the respective AML Compliance
Officer as listed in Appendix 1.
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Appendix 1
CIMB Group Reporting Institution
No.
-
Name of Reporting
Institution
CIMB Group Holdings
Berhad
Jurisdiction
Malaysia
Company
Registration
Number
706803-D
Anti-Money Laundering Compliance
Officer
Geetha Sivapathasundram
[email protected]
Ang Swee Leong
[email protected]
1
CIMB Bank Berhad
Malaysia
13491 - P
2
CIMB Islamic Bank
Berhad
Malaysia
671380 - H
3
CIMB Bank Berhad,
Labuan Offshore
Branch
Malaysia
13491-P/
090100D
(Licensed
Labuan Bank)
Subramaniam Vayaravasamy
[email protected]
Mary Tu Mei Ling
[email protected]
4
CIMB Bank (L) Limited
Malaysia
LL00104 /
930009A
(Licensed
Labuan Bank)
5
CIMB Commerce
Trustee Berhad
(formerly “BHLB
Trustee Berhad”)
Malaysia
313031 - A
Private Trust:
Tan Ping Ying
[email protected]
6
CIMB Islamic Trustee
Berhad (formerly “CIMB
Trustee Berhad”)
Malaysia
167913 - M
Corporate Trust:
Linda Ong Gaik Bee
[email protected]
7
CIMB Futures Sdn Bhd
Malaysia
257674 - P
Norhanizah Mohd Nor
[email protected]
8
CIMB Investment Bank
Berhad
Malaysia
18417 - M
Tan Gua Hui
[email protected]
9
CIMB Factor Lease Bhd
Malaysia
109053 - D
Baharudin Othman
[email protected]
10
CIMB Principal Asset
Management Berhad
Malaysia
304078 - K
11
CIMB Principal Islamic
Asset Management
Berhad
Malaysia
217841 - M
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Yap Ben Shiow
[email protected]
No.
Name of Reporting
Institution
Jurisdiction
12
CIMB Trust Ltd
Malaysia
Company
Registration
Number
LL04054 (Co. No)
/
LT0035 (Offshore
Bkg Licence No.)
13
Touch 'n Go Sdn Bhd
Malaysia
406400-X
Damian Lim Kwi Hoong
[email protected]
14
CIMB Middle East BSC
Bahrain
61558
Muhammad Bilal Aslam
[email protected]
15
CIMB Investment Bank
Berhad, Brunei
Darussalam
Brunei
AGO/RFC/731/06
(Reg Cert of Co.
Incorporated
outside Brunei
Darussalam)
Brian Wong Kwai Mun
[email protected]
16
CIMB Bank PLC
Cambodia
Co.1935E/2010
In Vansophea
[email protected]
17
CIMB Bank Berhad,
Shanghai Branch
China
310000500536146
Xu Bin Amy
[email protected]
18
CIMB Bank Berhad,
Hong Kong Branch
Hong Kong
F 20376
19
CIMB Securities Ltd
(formerly “CIMB
Securities
(HK) Ltd”)
Hong Kong
Cert. Incorporation
290697/Business
Reg. Certificate
14050536-000
20
CIMB Securities (India)
Pvt. Ltd
India
21
PT Bank CIMB Niaga
Tbk
Indonesia
Co. Identification
nos.
U65923MH2012P
TC237343
09.03.1.65.14394
(Reg No.) /
249544/U.M.II
(License No.)
22
PT CIMB-Principal
Asset
Management
Indonesia
Reg Cert (Tanda
Daftar
Perusahaan)
09.03.1.67.24923
Laura Orpa Tomarere
[email protected]
23
PT CIMB Securities
Indonesia
(formerly “PT CIMB-GK
Securities”)
Indonesia
09.03.1.67.25789
Achmad Aulia
[email protected]
Page 5 of 6
Anti-Money Laundering Compliance
Officer
Cheng Pau Yun
[email protected]
Rosa Leung
[email protected]
Shishir Karnik
[email protected]
Juliana Amelia Nehat
[email protected]
24
CIMB Securities Ltd,
Korea Branch
South Korea
Company
Registration
Number
101-84-06802
25
CIMB Thai Bank,
Vientiane Branch
Laos
264/ Jor Vor Tor
Narong Patwichaichoat
[email protected]m
26
CIMB Bank Berhad,
Singapore Branch
Singapore
S99FC5759D
Wong Foong Har
[email protected]
27
CIMB-Principal Asset
Management (S) Pte Ltd
Singapore
200607208K
Neo Wei Chiat
[email protected]
28
CIMB Securities
(Singapore)
Pte Ltd (formerly
“CIMB-GK
Securities Pte Ltd”)
Singapore
198701621D
Alvin Seah Kheng Seng
[email protected]
29
CIMB Investment Bank
(Private) Limited
Sri Lanka
PV 82537
Anarkali Moonesinghe
[email protected]
30
CIMB Securities Ltd,
Taiwan Branch
Taiwan
53665693
Carol Cheng
[email protected]
31
CIMB Thai Bank Public
Company Limited
Thailand
0107537002338
(Bor Mor Jor.480)
Thaphop Kleesuwan
[email protected]
32
CIMB Principal Asset
Management Company
Limited
Thailand
0105547164509
Pornpimol Changariyawong
[email protected]
33
CIMB Securities
(Thailand) Co.
Ltd (formerly “BT
Securities Ltd”)
Thailand
0105542081800
Khun Nakorn Lampaves
[email protected]
34
CIMB Bank Berhad,
London Branch
United
Kingdom
FC022225
Shaheed Sattar
[email protected]
35
CIMB Securities (UK)
Ltd
(formerly “CIMB-GK
Securities
(UK) Ltd”)
United
Kingdom
0271 9607
Helen Cai
[email protected]
36
CIMB Securities (USA)
Inc.
(formerly “CIMB-GK
Securities
(US) Inc”.)
United States
5219 71703
Helen Chin-Luk
[email protected]
No.
Name of Reporting
Institution
Jurisdiction
Last updated: 24 March, 2015
Page 6 of 6
Anti-Money Laundering Compliance
Officer
Tanny Kang
[email protected]