Dutch-Bangla Bank Limited

Central Compliance Unit

Head Office, Dhaka
Date:
QUESTIONNAIRE TO EVALUATE/TEST AML/CTF KNOWLEDGE STATUS
Name
:
Designation
:
Place of Posting :

ID No:
Date of Joining with DBBL:
Name of Desk
:

Year of last AML/CTF training received:

Mobile No
:

Blood Group

1. What do you understand by Money Laundering? What are the steps of Money Laundering

Money Laundering : money laundering is the process by which proceeds from a

criminal activity are disguised to conceal their illicit origins. Steps of Money
Laundering are as follows:
1. Placement 2. Layering 3. Integration
2. Does DBBL have policies and procedures approved by board or senior management to prevent money laundering
and combating terrorist financing? If, Yes please write the name of the Policy of DBBL

Ans: DBBL Manual on Prevention of Money Laundering and Terrorist

Financing (CTF), updated version, July, 2015
3. Does DBBL have a legal and regulatory compliance program that includes a designated officer that is responsible
for coordinating and overseeing the AML/CFT framework? If, Yes please write the name of Designation both
in Branch and Head Office

Ans: BAMLCO in Branch level and CAMLCO in Head Office-Central

Compliance Unit
4. Has DBBL developed written policies documenting the processes to prevent, detect and report suspicious
transactions?
YES/NO
5. Does DBBL 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.)
YES/NO
6. Does DBBL permit the opening of anonymous or numbered accounts by customers?
YES/NO
7. Does DBBL 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?
YES/NO
8. Does DBBL have policies covering relationships with Politically Exposed Persons (PEPs), their family and
close associates?
YES/NO
9. Does DBBL have policies and procedures that require keeping all the records related to customer identification
and their transactions? If Yes, for how long? 5 years from the date of account closure
When we have to keep unlimited time?
Ans: In case of suit file documents have to be kept for unlimited time.

10. Does DBBL have a risk-based assessment of its customer base and their transactions? If yes, write down the
parameters and what is the score of high risk identification

Ans: There are 7 parameters stated in AOF. Score of high risk identification is 14 and above
Parameter

Occupation/Nature of Business of the

Individual/Organization
Net worth of the Customer
Procurement of Accounts
Estimated monthly transactions
Estimated number of monthly transactions
Estimated monthly cash transactions
Estimated number of monthly cash transactions

Score against Risk

level
Low
Medi
High
um
0-2
3
4-5
0
0
0
0
0
0

1
1
1
1
1
1

3
3
3
3
3
3

Risk rating are calculated accumulating numbers obtained against risk

level of each parameter
Overall Risk grading :
Total Risk Rating Risk
Assessment
Above/Equal 14
High
Below 14
Low
11. Does DBBL determine the appropriate level of enhanced due diligence necessary for those categories of customers and
transactions for those that have reason(s) to pose a heightened risk of illicit activities at or through the FI?
YES/NO
Do you maintain files for PEPs and Influential Persons?

YES/NO

12. Has DBBL implemented processes for the identification of Beneficial Ownership (those customers on whose
behalf it maintains or operates accounts or conducts transactions)? If yes, please write briefly what do you
mean by Beneficial Owner

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(L) hw` Kvb ew Kvb MvnKK wbqY Ki m
(M) Kvvbxi wbqYKvix kqvi nvvi A_ev 20% ev Z`~a GKK kqvi
nvvi
Simple definition of Beneficial Owner- Beneficial owner refers to the natural
person(s) who ultimately owns or controls a customer and/or the natural person on whose
behalf a transaction is being conducted. It also includes those persons who exercise
ultimate effective control over a legal person or arrangement.
Which accounts should be consider for Beneficial Ownera) Normally company accounts- Beneficial owner will be those directors who hold 20% or
above shares of the company
b) Individual accounts having profession like student, House wife etc.
As per case study it is observed that there are some accounts in DBBL branches which
are used for applying IPO or regular share business where a single person (Beneficial
Owner) owns or controls those accounts.

13. Does DBBL have a requirement to collect information regarding its customers business activities? YES/NO
14. Does DBBL have a process to review and, where appropriate, update customer information relating to high risk
client information? If yes, then what is the frequency to update KYC of High Risk Account

Ans: At least once in a year to update KYC of High Risk Account

15. Does DBBL have procedures to establish a record for each new customer noting their respective identification
documents and Know Your Customer information?
YES/NO
16. Does DBBL complete a risk-based assessment to understand the normal and expected transactions of its
customers?
YES/NO
17. Does DBBL have policies or practices for the identification and reporting of transactions that are required to be
reported to the authorities?
YES/NO
18. Where cash transaction reporting is mandatory, does DBBL have procedures to identify transactions structured to
avoid such obligations?
YES/NO
19. Does DBBL screen customers and transactions against lists of persons, entities or countries issued by
government/competent authorities?
YES/NO
20. Write the name of the Sanction Lists you screen

Ans: Un, OFAC and Local

21. Do you affix seal on AOF & Remittance Vouchers and others ?

YES/NO

22. Does DBBL have policies to reasonably ensure that it only operates with correspondent banks that possess
licenses to operate in their countries of origin?
YES/NO
23. Does DBBL have a monitoring program for unusual and potentially suspicious activity that covers funds
transfers and monetary instruments such as travelers checks, money orders, etc?
YES/NO
24. How many STRs been filed by your branch? Ans:
25. Does DBBL provide AML& CFT training to relevant employees of your organization?

YES/NO

26. Does DBBL communicate new AML related laws or changes to existing AML related policies or practices to
relevant employees?
YES/NO
27. Does DBBL provide AML training to relevant third parties if they are employed to carry out some of the
functions of your organization?
YES/NO
28. What do you mean by escalation process of AML Reporting?

Ans: Escalation process means reporting process of ML/TF issues

Branch Officer BAMLCO CAMLCO Managing Director if
management give instruction CAMLCO to report to BFIU then CAMLCO
reports to BFIU accordingly