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Company Profile
Full address of the institution: 37A, Avenue J.F. Kennedy, L-1855 Luxembourg
Website Address: www.ubibanca.lu
Place of registration: Grand-Duchy of Luxembourg
Main Business (Retail banking, Corporate banking, Investment banking etc.): Private Banking & Commercial
Banking
Outline of History: member of the Italian banking group UBIBANCA, established October 1st, 1997 as
CAB International SA, on April 19th, 1999 name changed to Banca Lombarda International S.A.. On
July 21st, 2002 Artesia bank Luxembourg SA merged into the above. On June 26th, 2007 name
changed as above. On October 1st, 2007 BPU International SA merged into the above. During 2008
two foreign branches were opened in Munich (Germany) and Madrid (Spain) respectively
Affiliates, subsidiaries: -
Shareholder’s equity: -
Ratings: -
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-Is your bank authorized to hold foreign currency accounts outside of your country?: Yes
6) What type of financial products and services does your bank offer to your customers? :
All private banking and commercial banking products
-If YES, in which Stock Exchange Market(s) and what is your stock symbol? :
8) Please list names of the primary regulatory body(ies) that supervise(s) your institution.:
Commission de Surveillance du Secteur Financier (C.S.S.F.)
9) Are there any specific laws and/or regulations in place covering Anti-Money Laundering?: Yes
10) Do the laws / regulations in your jurisdiction limit or prohibit opening or maintenance of anonymous or
numbered accounts? : Yes
11) Has your bank been fined or received any enforcement action by your regulator for a breach of
Anti-Money Laundering legislation? : No
12) Please list names of your principal Shareholders and percentage of ownership who own more than 5%
shares of your bank.
Unione di Banche Italiane S.c.p.a. 93,01 %
Banca Popolare di Bergamo S.p.A. 3,46 %
Banco di Brescia S.p.A. 3,35 %
Banco di San Giorgio 0,18 %
100,00 %
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13) Please list names and titles of Executive Management:
Massimo AMATO, Managing Director
Ettore PEZZUTO, Joint Director General
Giancarlo PLEBANI, Joint Director General
14) Please describe your customers’ major business segments. Do they include the following business? : No
Casinos, Real estate agents, Dealers in precious metals and precious stones, Money Service Business,
Lawyers, notaries, other independent legal professionals and accountants, Trust and service providers.
15) Does your bank allow direct use of your correspondent accounts by your customers to transact business on
( X ) No. We do not allow direct use of our correspondent accounts by our customers to transact business on
their behalf.
15A) Have you verified the identity of and performed on-going due diligence on your customers having direct
access to your correspondent accounts?
15B) Are you able to provide relevant customer identification data upon request?
*Payable-through accounts:The above questions are based on Recommendation 7-(e) of FATF's "The Forty Recommendations".
The background of the question is that "pass through account" is considered by the regulators as high risk for potential money
laundering thus we need to verify that you have some kind of mechanism in place to reduce the risk of money laundering by
asking you the additional questions (15A) and (15B) .
16) Please fill in the attached “Wolfsberg AML Questionnaire”. If you have a ready-to-submit copy of the
answer to the questionnaire, please provide it (see enclosure).
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Financial Institution Name: UBI BANCA INTERNATIONAL S.A.
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.
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13. Does the FI have a requirement to collect information regarding Yx Nο
its customers’ business activities?
14. Does the FI assess its FI customers’ AML policies or practices? Yο Nο
FI customers are not within the bank’s range of customers
15. Does the FI have a process to review and, where appropriate, Yx Nο
update customer information relating to high risk client
information?
16. Does the FI have procedures to establish a record for each new Yx Nο
customer noting their respective identification documents and
‘Know Your Customer’ information?
17. Does the FI complete a risk-based assessment to understand Yx Nο
the normal and expected transactions of its customers?
IV. Reportable Transactions and Prevention and
Yes No
Detection of Transactions with Illegally Obtained Funds
18. Does the FI have policies or practices for the identification and Yx Nο
reporting of transactions that are required to be reported to the
authorities?
19. Where cash transaction reporting is mandatory, does the FI Yx Nο
have procedures to identify transactions structured to avoid
such obligations?
20. Does the FI screen customers and transactions against lists of Yx Nο
persons, entities or countries issued by government/competent
authorities?
21. Does the FI have policies to reasonably ensure that it only Yx Nο
operates with correspondent banks that possess licenses to
operate in their countries of origin?
V. Transaction Monitoring Yes No
22. Does the FI have a monitoring program for unusual and Yx Nο
potentially suspicious activity that covers funds transfers and
monetary instruments such as travelers checks, money orders,
etc?
VI. AML Training Yes No
23. Does the FI provide AML training to relevant employees that Yx Nο
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.
24. Does the FI retain records of its training sessions including Yx Nο
attendance records and relevant training materials used?
25. Does the FI communicate new AML related laws or changes to Yx Nο
existing AML related policies or practices to relevant
employees?
26. Does the FI employ third parties to carry out some of the Yο Nx
functions of the FI?
27. If the answer to question 26 is yes, does the FI provide AML Yο Nο
training to relevant third parties 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.
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.
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Space for additional information:
(Please indicate which question the information is referring to.)
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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.