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Section
Section 1: General information

Section 2: Regulatory and AML/CTF Compliance

Section 3: AML/CTF Policies and Procedures

and Enhanced Due Diligence (EDD)

Section 5: Transaction Monitoring and Reporting

Section 7: Politically Exposed Persons (PEPs) Screen

Section 8: Training and Awareness

Section 9: Record Keeping and Retention

Section 10: Independent Testing and Audit

Section 11: Additional Information and Declaration

Question
Institution Name:
Country of Incorporation:
Headquarters Location:
Licensing Authority:
Primary Business Activities:
Primary Contact Person:
Name:
Title:
Contact Details:
Is the
Has institution
the regulated
institution or any ofby
itsa affiliates
national been
authority for to
subject AML/CTF compliance?
regulatory action, fines,
or sanctions in the past five years for AML/CTF compliance violations?
Does the institution have a dedicated Money Laundering Reporting Officer (MLRO) or equivalent?
Does the institution have formal, board-approved AML/CTF policies and procedures?
Are these AML/CTF policies and procedures reviewed and updated regularly?
Do the policies and procedures cover the following areas:
Customer Due Diligence (CDD) and Know Your Customer (KYC)?
Enhanced Due Diligence (EDD) for high-risk customers?
Ongoing transactions monitoring?
Suspicious Transaction Reporting?
Sanctions
Does screening?have a risk-based approach to AML/CTF, prioritizing resources
the institution
basedyour
Does on customer and have
organisation transaction risk levels? risk assessment framework
an enterprise-wide
in place for AML/CTF compliance?
Is there a written risk assessment framework available?
Is this framework approved by the board or senior management?
Is the risk assessment aligned with any international standards? If so, which ones?
Does the risk assessment methodology incorporate scenario analysis and/or stress testing?
Whatthe
Does sources of datahave
institution are utilized for the
a customer purpose ofprogram
identification this risk that
assessment?
identities and verifies customer
during onboarding?
How do you identify and verify Ultimate Beneficial Owners?
At what
How andstages
when and howidentify
do you do youand
verify the source
verify of funds
information and/orcustomers’
regarding wealth?
business activities or professional status?
Is your
Does customer
the riskconduct
institution rating manually
EnhancedorDueautomatically generated?
Diligence (EDD) on high-risk customers
(e.g., PEPs, clients in high-risk jurisdictions)?
Does the institution perform ongoing due diligence to update and verify customer information regularly?
Does the
Please institution
describe have
in the a transaction
comment sectionmonitoring system
the transaction to detectsolutions
monitoring unusual or suspicious
that activities?
you are utiliying and
whether they are both on-chain and off-chain, and if not, why you don’t monitor one or the other.
Does the institution report suspicious transactions to the relevant Financial Intelligence Unit (FIU)
or similar authority?
What is the average timeline for investigating and reporting a suspicious transaction after detection?
Does the
Does the institution
institution screen
maintain an internal
customers, log of all suspicious
transactions, transactions
and counterparties reported
against to the FIU?sanctions
international
lists (e.g., OFAC, UN, EU, ISG, SECO)?
Does the
Does the institution
institution have
have policies
any clients in located
in place or operating
to prevent in sanctioned
transactions countries?
with sanctioned entities
and individuals?
Are real-time
Does sanctions
the institution screening
identify measures
and monitor in place
accounts for
for incomingExposed
Politically and outgoing transactions?
Persons (PEPs)
and their associates?
Are enhanced monitoring and reporting applied to transactions involving PEPs?
Does the institution provide AML/CTF training to all relevant employees?
Is AML/CTF training conducted?
Does the training program cover:
Customer Due Diligence (CDD) and Enhanced Due Diligence (EDD)?
Recognizing suspicious activities and transactions?
Reporting and escalation procedures?
Sanctions compliance?
Are training attendance records maintained for regulatory review?
Does the institution maintain records of customer transactions and due diligence information as required by regulation?
What is the standard retention period for these records?
Are records stored in a way that allows easy retrieval for audits or regulatory reviews?
Does the institution conduct regular, independent audits of its AML/CTF program?
What is the frequency of these audits?
Are audit findings and recommendations reported to senior management and the board?
Please provide AML/CTF Policy and any additional information relevant to your AML/CTF program in the comment section
Declaration: I hereby confirm that the information provided in this questionnaire is accurate and reflects
the current AML/CTF practices and policies of the institution.
Authorized Signatory:
Title:
Date:
Signature:
n 11

Answer

r equivalent?

ormation regularly?
ucious activities?
are utiliying and
or the other.
nce Unit (FIU)

after detection?
national sanctions

ormation as required by regulation?

/CTF program in the comment section

If yes, please specify the regulatory body

If yes, please specify the frequency (e.g., annually)

Please explain
Please explain
Please explain
Please explain
Please
If explain the criteria used for identifying high-risk customers:
yes, describe

If yes, specify the frequency:

Within 3 days
Other (please specify):
If yes, please specify:

Semi-annually
Other (please specify):

10 years
Other (please specify):

Bi-annually
Other (please specify)