wotfsberg group - himalayan bank...l"limalairan bank linltsd @ the wolfsberg group 2020 25 has the...
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wolfsberg Group correspondent Banking Due Diligence euestionnaire (cBDDe) v1.3
theWotfsberg
Group
Financial lnstitution Name:
Location (Country) :
ThequeStionnaireisrequiredtobeansweredonaLegalEn.ity(LE)Le,level including any branches for which the client base, products and control model are materially similar to the LE Head Office. This questionnaireshould not cover more than one LE. Each question in the CBDDQ will need to be addressed from the perspective of the LE and on behalf of all of itsbranches. lf a response for the LE differs for one of its branches, this needs to be highlighted and details regarding this difference captured at the endof each sub'section- lf a branch's business activity (products offered, client base etc.) is materially different than its Entity Head Office, a separatequestionnaire can be completed for that branch.
No# Question Answer1. EN: l Y &.OWN.ERS}||P,| ull Legal Name
Himalayan Bank Limited
2 \ppend a list of foreign branches which are:overed by this questionnaire All Branches, List of Branches in this Link: https://www.himalayanbank.com/branch
Full Legal (Registered) AddressKathmandu Metropolitan City, Ward No. 28, Kamaladi Kathmandu, Nepal
Full Primary Business Address (if different fromabove) Kathmandu Metropolitan City, Ward No. 28, Kamaladi Kathmandu, Nepal
Date of Entity incorporation/ establishment1992 Feburary 16
.{a
6 Select type of ownership and append anownership chart if available
6a Publicly Traded (25o/o of shares publicly traded)Yes
6a1 lf Y, indicate the exchange traded on and tickersymbol Nepal Stock Exchange Limited (NEPSE)
6b Member Owned/ MutualNo
6c Government or State Owned by 25o/o or moreNo
5d Privately OwnedNo
5dl lf Y, provide details of shareholders or ultimatebeneficial owners with a holding of lOo/o or more
N/A
7 % of the Entity's total shares composed ofbearer shares N/A
Does the Entity, or any of its branches, operateunder an Offshore Banking License (OBL) ? No
3a lf Y, provide the name of the relevant branch/eswhich operate under an OBL
Name of primary financial regulator / supervisoryauthority Nepal Rastra Bank
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10 )rovide Legal Entity ldentifier (LEl) if available
11 Provide the full legal name of the ultimate parent(if different from the Entity completing the DDQ)
N/A
12 Jurisdiction of licensing authority and regulatorof ultimate parent
N/A
3 Select the business areas applicable to theEntity
13 a Retail BankingYes
13b )rivate Banking / Wealth ManagementNo
13 c lommercial BankingYes
13d fransactional BankingYes
'13 e lnvestment BankingNo
13 f Financial Markets TradingYes
139 Securities Services / CustodyNo
13 h 3roker / DealerNo
13 Vlultilateral Development BankNo
13 j f,ther
14 Does the Entity have a significant (10% or more)portfolio of non-resident customers or does itderive more than '10% of its revenue from non-resident customers? (Non-resident meanscustomers primarily resident in a differentjurisdiction to the location where bank servicesare provided.)
trr
No
14a lf Y, provide the top five countries where the non-resident customers are located.
15 Select the closest value:
15 a Number of employees501 -1 000
'15 b TotaI ASSetSGreater than $500 million
16 Confirm that all responses provided in the aboveSection ENTITY & OWNERSHIP arerepresentalive of all the LE's branches
Yes
16a lf N, clarify which questions the difference/srelate to and the branch/es that this applies to.
16b lf appropriate, provide any additional information/ context to the answers in this section.
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2. FRODUGfS $,$sRVl6[$17 foes the Entity offer the following products and
iervices:
't7 a Jorrespondent BankingNo
17 a1 fY
17 a2 )oes the Entity offer Correspondent Banking;ervices to domestic banks? No
17 a3 Does the Entity allow domestic bank clients toprov ide downstream relationships? No
17 a4 Does the Entity have processes and proceduresin place to identify downstream relationshipswith domestic banks?
No
'17 a5 foes the Entity offer correspondent banking;ervices to Foreign Banks? No
17 aG )oes the Entity allow downstream relationshipsrvith Foreign Banks? No
17 a7 Does the Entity have processes and proceduresin place to identify downstream relationshipswith Foreign Banks?
No
17 aB )oes the Entity offer correspondent banking;ervices to regulated MSBs/MVTS? No
17 a9 )oes the Entity allow downstream relationshipswith MSBs/MWS? No
17 a'10 )oes the Entity have processes and proceduresn place to identify downstream relationships,Vith MSB /MVTS?
No
17b )rivate Banking (domestic & international)No
17c Trade FinanceYes
17d rayable Through AccountsNo
17e Stored Value lnstrumentsNo
17t lross Border Bulk Cash DeliveryNo
17g )omestic Bulk Cash DeliveryNo
6
17h lnternational Cash LetterNo
17i Remote Deposit CaptureNo
't7 j /irtual /Digital CurrenciesNo
17k -ow Price SecuritiesNo
'17 I Hold MailNo
't7 m lross Border Rem ittancesYes
17n Service to walk-in customers (non-accountholders) Yes
17o Sponsoring Private ATMsNo
17p Other high risk products and services identifiedby the Entity
No
8 Confirm that all responses provided in the aboveSection PRODUCTS & SERVICES arerepresentative of all the LE's branches
Yes
8a lf N, clarify which questions the difference/srelate to and the branch/es that this applies to
,t8 b lf appropriate, provide any additional information/ context to the answers in this section.
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3. AML;,CfF & .S,ANGT|O NS,,pp96*AMME19 Does the Entity have a programme that sets
minimum AML, CTF and Sanctions standardsregarding the following components:
19 a Appointed Officer with sufficientexperience/expertise Yes
9b Cash ReportingYes
19 c CDDYes
19d EDDYes
19 e Beneficial OwnershipYes
't9 f lndependent TestingYes
199 Periodic ReviewYes
19h Policies and ProceduresYes
19 i Risk AssessmentYes
1sj SanctionsYes
19 k PEP ScreeningYes
19t Adverse lnformation ScreeningYes
9m Suspicious Activ ity ReportingYeS
19 n Training and EducationYes
19o Transaclion Mon itoringYes
20 How many full time employees are in the Entity'sAML, CTF & Sanctions ComplianceDepartment?'
Less than 10
21 ls the Entity's AML, CTF & Sanctions policyapproved at least annually by the Board orequivalent Senior Management Committee?
Yes f,}.
22 Does the Board or equivalent SeniorManagement Committee receive regularreporting on the status of the AMt-, CTF &Sanctions programme?
Quarterly/Every three months
23 Does the Entity use third parties to carry out anycomponents of its AML, CTF & Sanctionsprogramme?
No
23a lf Y, provide further details
24 Confirm that all responses provided in the aboveSection AML, CTF & SANCTIONS Programmeare representative of all the LE's branches
Yes
24a lf N, clarify which questions the difference/srelate to and the branch/es that this applies to.
24b tf appropriate, provide any additional information/ context to the answers in this section.
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l"limalairan Bank Linltsd
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25 Has the Entity documented policies andprocedures consistent with applicable ABCregulations and requirements to [reasonably]prevent, detect and report bribery andcorruotion?
Yes
26 Does the Entity have an enterprise wideprogramme that sets minimum ABC standards?
No
27 Has the Entity appointed a designated officer orofficers with sufficient experience/expertiseresponsible for coordinating the ABCproqramme?
Yes
28 Does the Entity have adequate staff withappropriate levels of experience/expertise toimplement the ABC programme?
Yes
29 ls the Entity's ABC programme applicable to: Third parties acting on behalf of the Entity
30 Does the Entity have a global ABC policy that:
]0a Prohibits the giving and receiving of bribes?This includes promising, offering, giving,solicitation or receiving of anything of value,directly or indirectly, if improperly intended toinfluence action or obtain an advantage
Yes
30b ncludes enhanced requirements regardingnteraction with public officials?
Yes
a0c ncludes a prohibition against the falsification oflooks and records (this may be within the ABCrolicy or any other policy applicable to the Legalintitv)?
Yes
31 )oes the Entity have controls in place to monitor:he effectiveness of their ABC programme? Yes
32 Does the Entity's Board or Senior ManagementCommittee receive regular Managementlnformation on ABC matters?
Yes
!3 Does the Entity perform an Enterprise WideABC risk assessment?
No
13a lf Y select the frequency
,4 Does the Entity have an ABC residual risk ratingthat is the net result of the controls effectivenessand the inherent risk assessment?
No
]5 Does the Entity's ABC EWRA cover the inherentrisk components detailed below:
35a Potential liability created by intermediaries andother third-party providers as appropriate
Yes
35b Corruption risks associated with the countriesand industries in which the Entity does business,directly or through intermediaries
Yes
35c lransactions, products or services, including:hose that involve state-owned or state-:ontrolled entities or public officials
Yes
35d Sorruption risks associated with gifts androspitality, hiring/internships, charitablelonations and political contributions
Yes
35e Changes in business activities that maymaterially increase the Entity's corruption risk
Yes
36 Does the Entity's internal audit function or otherindependent third party cover ABC Policies andProcedures?
Yes
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37 Ooes tne Entity provide mandatory ABC training
to:
17a joard and senior Committee Management Yes
37b 1st Line of Defence Yes
37c
37d
2nd Line of Defence Yes
3rd Line of Defence Yes
37e 3rd parties to which specific complianceactivities subject to ABC risk have been
outsourced
Yes
t7t rlon-employed workers as appropriatelcontractors/consu ltants)
Yes
38 Ooes tfie entity provide ABC training that is
targeted to specific roles, responsibilities and
activities?
Yes
39 Confirm that all responses provided in the above
Section Anti Bribery & Corruption are
representative of all the LE's branchesYes
39a tt t t, ctarfy wnich questions the difference/srelate to and the branch/es that this applies to.
39b f appropriate, provide any additional information
'context to the answers in this section'
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5. AML,40
CTF & SANCTIONS POLICIES_& PROCEHas the Entity documented policies andprocedures consistent with applicable AMI_, CTF& Sanctions regulations and requirements toreasonably prevent, detect and report:
)URES
40a Money launderingYes
40b ferrorist financingYes
40c Sanctions violationsYes
1 Are the Entity's policies and procedures updatedat least annually? Yes
t2 Are the Entity's policies and procedures gappedagainsl/compared to:
12a US StandardsNo
2a1 lf Y, does the Entity retain a record of theresults?
t2b EU StandardsNo
12 b1 lf Y, does the Entity retain a record of theresults?
t3 Does the Entity have policies and proceduresthat:
t3a Prohibit the opening and keeping of anonymousand fictitious named accounts Yes
13b Prohibit the opening and keeping of accounts forunlicensed banks and/or NBFIs Yes
43c Prohibit dealing with other entities that providebanking services to unlicensed banks Yes
3d )rohibit accounts/relationships with shell banksYes
43e )rohibit dealing with another entity that provides;ervices to shell banks Yes
43f Prohibit opening and keeping of accounts forSection 31'l designated entities
sYes439 Prohibit opening and keeping of accounts for
any of unlicensed/unregulated remittanceagents, exchanges houses, casa de cambio,bureaux de change or money transfer agents
Yes
3h Assess the risks of relationships with domesticand foreign PEPs, including their family andclose associates
Yes
3i Define escalation processes for financial crimerisk issues Yes
f3j Define the process, where appropriate, forterminating existing customer relationships dueto financial crime risk
Yes
{3k Specify how potentially suspicious activityidentified by employees is to be escalaled andinvestigated
Yes
43 I Outline the processes regarding screening forsanctions, PEPs and negative media Yes
43m Outline the processes for the maintenance olinternal "watchlists" Yes
44 Has the Entity defined a risk tolerance statementor similar document which defines a riskboundary around their business?
Yes
45 Does the Entity have a record retentionprocedures that comply with applicable laws? Yes
45a lf Y, what is the retention period?5 years or morgr..
46 Confirm that all responses provided in the aboveSection POLICIES & PROCEDURES arerepresentative of all the LE's branches
Yes
46a lf N. clarify which questions the difference/srelate to and the branch/es that this applies to.
46b appropriate, provide any additional informationcontext to the answers in this section.
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, A M,L,,,GIF &.. SA.NG:TI O N S. RIS K., A S SESSMEN T
47 )oes the Entity's AML & CTF EWRA cover thenherent risk components detailed below:
L7a ClientYeS
t7b ProductYes
17c ChannelYes
47d 3eographyYes
48 Does the Entity's AMt & CTF EWRA cover thecontrols effectiveness components detailed
below:
lUa Transaction MonitoringYeS
48b Customer Due Diligence Yes
48c )EP ldentification Yes
t8d Transaction Screening Yes
18e Name Screening against Adverse Media &Negative News
Yes
+Ef fraining and Education Yes
489 3overnance Yes I
48h Management I nformation Yes
49 Has the Entity's AML & CTF EWRA beencompleted in the last 12 months?
Yes
{9a lf N, provide the date when the last AML & CTFEWRA was comlleted.
fit
50 Does the Entity's Sanctions EWRA cover theinherent risk components detailed below:
i0a ClientYes
50b ProductYes
50c lhannelYes
50d Geography Yes
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51 Does the Entity's Sanctions EWRA cover thecontrols effectiveness componenls detailedbelow:
51 a Customer Due DiligenceYes
51 b Transaction ScreeningYes
1c Name ScreeningYes
51 d List ManagementYes
51 e Training and EducationYes
51 f SovernanceYes
519 Vlanagement lnformationYes
52 las the Entity's Sanctions EWRA been;ompleted in the last 12 months? Yes
52a N, provide the date when the last SanctionsWRA was completed.
i3 Confirm that all responses provided in the aboveSection AMt, CTF & SANCTTONS R|SKASSESSMENT are representative of all the LE'sbranches
YeS
53a lf N, clarify which questions the difference/srelate to and the branch/es that this applies to.
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53b lf appropriate, provide any additional information/ context to the answers in this section.
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. KYC, CDD'and,EDD54 Does the Entity verify the identity of the
customer?Yes
55 Jo the Entity's policies and procedures set out.l/hen CDD must be completed, e.g. at the time
)f onboarding or within 30 daYsYes
56 Which of the following does the Entity gather
and retain when conducting CDD? Select all that
apply:
56a Ownership structureYes
56b ustomer identificationYes
56c Expected activity Yes
56d Natu re of business/emPloymentYes
56e )roduct usageYes
s6f Purpose and nature of relationship Yes
569 Source of funds Yes
56h Source of wealthYes
i7 Are each of the following identified:
57a Ultimate beneficial ownershiP IYes
57 a1 \re ultimate beneficial owners verified? Yes
57b Authorised signatories (where applicable) Yes
7c Key controllers Yes
57d Other relevant parties lb
58 What is the Entity's minimum (lowest) threshold
applied to beneficial ownership identification ?10%
59 )oes the due diligence process result inlustomers receiving a risk classification?
Yes
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50 lf Y, what faclors/criteria are used to determinethe customer's risk classification? Select all thatapply:
50a )roduct UsageYes
30b 3eographyYes
50c 3usiness Type/lndustryYes
30d -egal Entity typeYes
50e Adverse lnformationYes
30f )ther (specify)
1 )oes the Entity have a risk based approach to;creening customers for adversenedia/negative news?
Yes
2 f Y, is this at:
i2a )nboardingYes
2b (YC renewalYes
82c Irigger eventYes
B3 il/hat is the method used by the Entity to screenbr adverse media / negative news? Combination of automated and manual
54 )oes the Entity have a risk based approach toscreening customers and connected parties toletermine whether they are PEPs, or controlledly PEPs?
Yes
B5 lf Y, is this al
65a )nboardingYes tr
65b (YC renewalYes
65c l-rigger eventYes
Db /Vhat is the method used by the Entity to screen:EPS? Combination of automated and manual
67 )oes the Entity have policies, procedures andlrocesses to review and escalate potentialTatches from screening customers andlonnected parties to determine whether they are)EPs, or controlled by PEPs?
Yes
B8 foes the Entity have a process to review and;pdate customer information based on:
88a (YC renewalYes
E8b rigger eventYes
B9 )oes the Entity maintain and report metrics onlurrent and past periodic or trigger event dueJiligence reviews?
Yes
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70 :rom the list below, which categories oflustomers or industries are subject to EDDend/or are restricted, or prohibited by the Entity's:CC programme?
70a \on-account customersEDD on a risk based approach
r0b \on-resident customersEDD on a risk based approach
70c Shell banksProhibited
70d VIVTS/ MSB customersEDD on a risk based approach
70e )EPsEDD on a risk based approach
70f rEP RelatedF-DD on a risk based approach
7og PEP Close AssociateEDD on a risk based approach
70h Correspondent BanksEDD on a risk based approach
70 hl lf EDD or EDD & restricted, does the EDDassessment contain the elements as set out inthe Wolfsberg Correspondent BankingPrinciples 2014?
Yes
70i Arms, defense, militaryProhibited
70j Atomic powerProhibited
zok Extractive industriesEDD on a risk based approach
0t Precious metals and stonesEDD on a risk based approach
70m Unregulated charitiesProhibited
70n Regulated charitiesEDD on a risk based approach
0o Red light business / Adult entertainmenlProhibited
op Non-Government OrganisationsEDD on a risk based approach
0q Virtual currenciesProhibited
0r MarijuanaProhibited
70s Em bassies/Consu latesEDD on a risk based approach
70t GamblingProhibited
70u ayment Service ProviderEDD on a risk based approach
70v )ther (specify)
71 lf restricted, provide details of the restriction
72 Does the Entity perform an aclclitional control orquality review on clients subject to EDD? Yes
73 Confirm that all responses provided in the aboveSection KYC, CDD and EDD are representativeof all the LE's branches
Yes
73a lf N, clarify which questions the difference/srelate to and the branch/es that this applies to
73b lf appropriate, provide any additional information/ context to the answers in this section.
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t4 )oes the Entity have risk based policies,)rocedures and monitoring processes for thedentification and reporting of suspiciousrctivity?
Yes
5 What is the method used by the Entity tomonitor transactions for suspicious activities? Combination of automated and manual
t6 lf manual or combination selected, specify whatlype of transactions are monitored manually
Based on the triggers/alerts generated by Transaction Monitoring software, details and rationale orthe transaction is monitored manually for further investigation and regulatory reporting purpose.Dedicated staff go through the alerts, investigate and if necessary escalate for further decision.
t7 Does the Entity have regulatory requirements toreport suspicious transactions? Yes
la lf Y, does the Entity have policies, proceduresand processes to comply with suspicioustransaction reporting requirements?
Yes
r8 Does the Entity have policies, procedures andprocesses to review and escalate mattersarising from the monitoring of customertransactions and activity?
Yes
t9 Confirm that all responses provided in the aboveSection MONITORING & REPORTING arerepresentative of all the LE's branches
Yes
79a lf N, clarify which questions the difference/s.relate to and the branch/es that this applies to
/9b lf appropriate, provide any additional information/ context to the answers in this section.
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$i:i:P*vlilEN:fri:TR NSFATRENSY80 Does the Entity adhere to the Wolfsberg Group
Paym ent Transparency Standards?Yes
81 Does the Entity have policies, procedures andprocesses to [reasonably] comply with and have
controls in place to ensure compliance with:
B1 a FATF Recommendation 16Yes
1b -ocal Regulations Yes
1bl Specify the regulation Assets Laundering and Prevention ActAML RulesCentral Bank GuidelinesFIU Guidelines
1c f N, explain
82 Does the Entity have processes in place to
respond to Request For lnformation (RFls) fromother entities in a timely manner?
Yes
33 Does the Entity have controls to support theinclusion of required and accurate originatorinformation in international payment messages?
Yes
B4 Does the Entity have controls to support the
inclusion of required beneficiary informationinternational payment messages?
Yes
t5 Confirm that all responses provided in the aboveSection PAYMENT TRANSPARENCY are
representative of all the LE's branchesYes
35a f N, clarify which questions the difference/s'elate to and the branch/es that this applies to,
65b lf appropriate, provide any additional information/ context to the answers in this section. t
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l-.fiiffil [-Sffl.s,i|tlSjf; #$iifi liiiff ilifi #iiffi mi#lliliiliilf i:$XiIIi#ni1ffi fr $,fr I#l illiir*fillilllillliili86 Does the Entity have a Sanctions Policy
approved by management regardingcompliance with sanctions law applicable to theEntity, including with respect its businessconducted with, orthrough accounts held atloreign financial institutions?
Yes
87 Does the Entity have policies, procedures, orother controls reasonably designed to preventthe use of another entity's accounts or servicesin a manner causing the other entity to violatesanctions prohibitions applicable to the otherentity (including prohibitions within the otherentity's local jurisdiction)?
Yes
B8 Does the Entity have policies, procedures orother controls reasonably designed to prohibitand/or detect actions taken to evade applicablesanctions prohibitions, such as stripping, or theresubmission and/or masking, of sanctionsrelevant information in cross borderlransactions?
Yes
89 Does the Entity screen its customers, includingbeneficial ownership information collected by theEntity, during onboarding and regularlythereafter against Sanctions Lists?
Yes
90 What is the method used by the Entity?Combination of automated and manual
91 )oes the Entity screen all sanctions relevantlata, including at a minimum, entity and locationnformation, contained in cross border:ransactions against Sanctions Lists?
Yes
s2 What is the method used by the Entity?Combination of automated and manual
,3 Select the Sanctions Lists used by the Entity inits sanctions screening processes:
,3a Consolidated United Nations Security CouncilSanctions List (UN) Used for screening customers and beneficial owners anii. for flltering transactional data
93b United States Department of the Treasury'sOffice of Foreign Assets Control (OFAC) Used for screening customers and beneficial owners and for filtering transactional data
93c f,ffice of Financial Sanctions lmplementationrMT (OFSt) Used for screening customers and beneficial owners and for filtering transactional data
93d Suropean Union Consolidated List (EU)Used for screening customers and beneficial owners and for filtering transactional data
,3e Lists maintained by other G7 member countries e veePr ;{APAN,93f Other (specify)
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95 When regulatory authorities make updates totheir Sanctions list, how many business daysbefore the entity updates their active manual and/or automated screening systems against:
l5a Customer Data
Same day to 2 business days
95b fransactions
Same day to 2 business days\.
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96 Does the Entity have a physical presence, e.9.,branches, subsidiaries, or representative officeslocated in countries/regions against which UN,OFAC, OFSI, EU and G7 member countrieshave enacted comprehensive jurisdiction-based
Sanctions?
No
7 Confirm that all responses provided in the aboveSection SANCTIONS are representative of allthe LE's branches
Yes
17a lf N, clarify which questions the difference/srelate to and the branch/es that this applies to.
)7b f appropriate, provide any additional information'conlext to the answers in this section.
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I1. TRAINING .& EDUCATI.ON,8 Does the Entity provide mandatory training,
which includes :
18a ldentification and reporting of transactions togovernment authorities Yes
,8b Examples of different forms of moneylaundering, terrorist financing and sanctionsviolations relevant for the types of products andservices offered
Yes
,8c lnternal policies for controlling moneylaundering, terrorist financing and sanctionsviolations
Yes
,8d New issues that occur in the market, e.9.,significant regulatory actions or new regulations Yes
)8e Conduct and CultureYes
,9 ls the above mandatory training provided to
,9a Board and Senior Committee ManagementYes
)9b 1st Line of DefenceYes
)9c 2nd Line of DefenceYes
t9d 3rd Line of DefenceYes
)9e 3rd parties to which specific FCC activities havebeen outsourced Yes b
l9f Non-employed workers(contractors/con su ltan ts) Yes
100 Does the Entity provide AML, CTF & Sanctionstraining that is targeted to specific roles,responsibilities and high risk products, servicesand activities?
Yes
101 Does the Entity provide customised training forAML. CTF and Sanctions staff? Yes
102 Confirm that all responses provided in the aboveSection TRAINING & EDUCATION arerepresentative of all the LE's branches
Yes
'102 a lf N, clarify which questions the difference/srelate to and the branch/es that this applies to.
'to2 b lf appropriate, provide any additional information/ context to the answers in this section.
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lti2l:iQt : |"TV.IASS:I}RANGE.I/0:OTMF,EIAN,GE TEST|NG103 Are the Entity's KYC processes and documents
subject to quality assurance testing? Yes
104 Does the Entity have a program wide risk basedCompliance Testing process (separate to theindependent Audit function)?
Yes
105 Confirm that all responses provided in the aboveSection QUALITY ASSURANCE /COMPLIANCE TESTING are representative ofall the LE's branches
Yes
105 a lf N, clarify which questions the difference/srelate to and the branch/es that this applies to.
105 b f appropriate, provide any additional information
'context to the answers in this section.
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13, AUDTT---+r_'t 06 ln addition to inspections by the government
supervisors/regulators, does the Entity have aninternal audit function, a testing function or otherindependent thircl party, or both, thal assessesFCC AML, CTF and Sanctions policies andpractices on a regular basis?
Yes
107 How often is the Entity audited on its AML, CTF& Sanctions programme by the following:
107 a lnternal Audit DepartmenlYearly
107 b External Third PartyYearly
08 Does the internal audit function or otherindependent third party cover the followingareas:
108 a AML, CTF & Sanctions policy and proceduresYes
108 b KYC / CDD / EDD and underlyingmethodologies Yes
108 c Transaction MonitoringYes
108 d Transaction Screening including for sanctionsYes
10E e \ame Screening & List ManagementYes
108 f Iraining & EducationYes
108 g TechnologyYes
108 h 3overnanceYes
108 i leporting/Metrics & Management lnformationYes
108 j Suspicious Activity Filing
{xYes
108 k nterprise Wide Risk AssessmentYes
108 I Other (specify)
109 Are adverse findings from internal & externalaudit tracked to completion and assessed foradequacy and completeness?
Yes
10 Confirm that all responses provided in the abovesection, AUDIT are representative of all the LE'sbranches
Yes
110 a lf N, clarify which questions the difference/srelate to and the branch/es that this applies to
110 b lf appropriate, provide any additional information/ context to the answers in this section.
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@ The Wolfsberg Group 2020 Page 19 CBDDQ V1-3
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Wolfsberg Group Correspondent Banking Due Diligence Questionnaire (CBDDO) V1.3
laration Statement
Group Correspondent Banking Due Diligence Questionnaire 2020 (CBDDQ V1 .3)
Statemenl (To be signed by Global Head of Correspondent Banking or equivalent position holder AND Group Money Laundering Prevention Officer, Global Head ofMoney Laundering, Chief Compliance Officer, Global Head of Financial Crimes Compliance OR equivalent)
H irnalayan: tsank Lir,h ited(Financial lnstitution name) is fully committed to the fight against financial crime and makes
and regulatory obligations.
he information provided in thiswolfsberg CBDDQ will be kept current and will be u.pdated no less frequently than on an annual basis.
'he Financial lnstitution commits to file accurate sudiplemental information on a timely basis.
BhaWa,ni Gh'imire(Global Head of Correspondent Banking or equivalent), certify that I have read and understood this declaration, that ,
answers provided in this Wolfsberg CBDDQ are complete and conect to my honest belief, and that I am authorised to execute this declaration on behalf of the Financial
FrakaSh Bhahdari ' , (MLRO or equivalent), certify tha d understood this declaration, that the answers provided in thisCBDDQ are complete 2nd correct to my hohest belief, and that I am authorised to tion on behalf of the Financial lnstitution.
u (Signature & Date)
q NY a2f lq qy'1fr'7-D(Sisnature& Date) Himalavan Bank Limited
FrI
ei@ The Wolfsberg
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CBDDO