The Wolfsberg Group consists of the following leading international financial institutions: Banco Santander, Bank of Tokyo-Mitsubishi
UFJ, Barclays, Citigroup, Credit Suisse, Deutsche Bank, Goldman Sachs, HSBC, JP Morgan Chase, Société Générale and UBS which
aim to develop financial services industry standards, and related products, for Know Your Customer, Anti-Money Laundering and
Counter Terrorist Financing policies.
Anti-Money Laundering Questionnaire
If you answer “no” to any question, additional information can be supplied
at the end of the questionnaire.
I. General AML Policies, Practices and Procedures:
1. Is the AML compliance program approved by the FI’s board or a
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
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
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