SELF - RESPONDED ANTI-MONEY LAUNDERING (AML) AND KNOW YOUR CUSTOMER (KYC) QUESTIONNAIRE
| A. ENTITY AND OWNERSHIP | |
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| Full registered name | LAND BANK OF THE PHILIPPINES |
| Business address | LANDBANK Plaza 1598 M. H. Del Pilar cor Dr. J. Quintos Streets Malate, Manila 1004 Philippines |
| Contact Number/s | +63 2 5512200/ 5220000 |
| Web Address | www.landbank.com |
| TIN (Tax ID No.) | 000-470-349-000 |
| Corporate Legal Form | Government Financial Institution |
| Registration/License No. | LBP was created by kaw, specifically by virtue of R.A. 3844 (Agricultural Land Reform Code of 1963, passed on 08 August 1963), as amended by R.A. 10374 (An Act Extending the Life of the Land Bank of the Philippines, passed on 05 March 2013). Pursuant to Section 97 of R.A. 3844, LBP is under the supervision and regulation of the Central Bank of the Philippines (now BSP). In lieu of the registration/license number, please visit www.lawphil.net for the copy of the enabling law. |
| Type of license for performing banking operations, issuing body | Universal Bank issued by Bangko Sentral ng Pilipinas (BSP) |
| Number of branches/ banking units | For the branches and extension offices, please refer to our website https://www.landbank.com/corporate-profile Network section For the subsidiaries, https://www.landbank.com/foundation-subsidiaries |
| Board of Directors | Please refer to our website https://www.landbank.com/board-of-directors |
| Senior Management | Please refer to our website https://www.landbank.com/board-of-directors |
| Does your institution have any Politically Exposed Persons in the management? | Yes |
| Names of legal entity or persons who own more than 10% of the shares in your company | LBP is 100% owned by the government of the Republic of the Philippines. |
| Is your institution listed in a stock exchange? Please name the stock exchange. | No. |
| Name of the primary financial regulator / supervisory authority | Bangko Sentral ng Pilipinas (BSP) and Anti-Money Laundering Council (AMLC) |
| Select the business areas applicable to the Entity | |
| Retail Banking | Yes |
| Private Banking/ Wealth management | No |
| Commercial Banking | Yes |
| Transactional Banking | Yes |
| Investment Banking | Yes |
| Financial Markets Trading | Yes |
| Securities Services/ Custody | Yes |
| Broker/Dealer | Yes |
| Multilateral Development Bank | No |
| Other | Please refer to our official website @ www.landbank.com |
| Number of employees | 8.767 as of 22 May 2019 |
| Total Assets | Between $10 and $100 million as of 31 Dec 2018 |
| B. AML, CTF & SANCTIONS PROGRAMME | YES | NO | ||||||||||||||||
| I. General AML Policies, Practices and Procedures | ||||||||||||||||||
| 1. | Is money laundering a crime in the country where your institution is registered/located? |  |
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| 2. |
Name of the law that regulates Anti-Money Laundering (AML) and Terrorist Financing country in which your institution is located: Republic Act (RA) No. 9160, otherwise known as the Anti-Money Laundering Act of 2001, as amended by the foloowing: R.A 9194 - An Act Amending Republic Act No. 9160 R.A 910365 - Ac Act to Further Strengthen the Anti-Money Laundering Law; |
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| 3. | Name of official entity/agency that regulates anti-money laundering activities in your Country: Anti-Money Laundering Council (AMLC) |
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| 4. | Does your institution have written guidelines to prevent, detect and report covered and suspicious transactions that has been approved by senior management? | |
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| 5. |
Does your institution have a legal and regulatory AML compliance program that includes a designated officer that is responsible for coordinating and overseeing the AML framework which have been approved by the institutions board, senior management or a senior committee? If yes, please provide the following details pertaining to such responsible officer:
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| 6. | In addition to inspections by the government supervisors/regulators, does the institution’s client have an internal audit function or other independent third party that assesses AML policies and practices on a regular basis? LBP's Internal Audit Group - Annual review |
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| 7. | Does your institution maintain any anonymous or numbered accounts? If yes, please explain. | |
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| 8. | Does your institution allow direct use of a correspondent account by third party (e.g., payable-through account)? If yes, please explain. | |
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| 9. | Does your institution provide services to shell banks/institutions (banks/institutions with no physical presence in any jurisdiction)? If yes, please explain. | |
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| 10. | Does your institution have policies covering relationships with Politically Exposed Persons (PEP’s), consistent with industry best practices? | |
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| 11. | Do regulations in your country require that your institution report transactions in excess of a given amount and/ or any suspicious transaction to an agency established for such purpose? | |
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| 12. | Does your institution require that records of your customer's KYC information and transactions be maintained for a period of time? If yes, please indicate retention period. Minimum Retention Period: Five (5) Years per AMLA |
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| 13. |
Does your institution require that it’s AML policies and practices be applied to all branches and subsidiaries? |
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| 14. | Has any action been brought against your institution for violation of laws or regulations on terrorist financing and/or money laundering? If Yes, please explain. | |
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| 15. | Is your institution fully compliant with the FATF 49 recommendations? | |
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| II. Risk Assessment | ||||||||||||||||||
| 16. | Does your institution have a risk-based assessment of its customer base and their transactions? | |
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| 17. | Does your institution determine the appropriate level of enhanced due diligence necessary for those categories of customers and transactions that the institution has reason to believe pose a heightened risk of illicit activities at or through the institution? | |
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| III. Know Your Customer, Due Diligence and Enhanced Due Diligence | ||||||||||||||||||
| 18. | Does your institution mandate verification of the true identity of all customers at the inception of any business relationship and on an ongoing basis? | |
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| 19. | Has your institution implemented processes for the identification of those customers in whose behalf it maintains or operates accounts or conducts transactions? | |
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| 20. | Are reasonable measures taken to obtain information about the legitimacy of client's activities and sources of funds? | |
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| 21. | Does your institution have procedures to establish a record for each new customer noting their respective identification documents and "Know Your Customer" information? | |
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| 22. | Does your institution assess its financial institution customers’ AML policies and practices? | |
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| 23. | Does your institution complete a risk-based assessment to understand the normal and expected transactions of its customers? | |
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| IV. Reportable Transactions and Prevention and Detection of Transactions with Illegally Obtained Funds | ||||||||||||||||||
| 24. | Does your institution have policies or practices for the identification and reporting of transactions that are required to be reported to the authorities? | |
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| 25. | Where cash transaction reporting is mandatory, does your institution have procedures to identify transactions structured to avoid such obligations? | |
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| 26. | Does your system checks the list of individuals and entities under financial measures and/or suspected of terrorist activities to ensure that none of the counterparty is on the list (OFAC-SDN/FATF-NCCT)? | |
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| 27. | Does your institution have policies to reasonably ensure that it only operates with correspondent banks that possess licenses to operate in their countries of origin? | |
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| 28. | Does the FI adhere to the Wolfsberg Transparency Principles and the appropriate usage of the SWIFT MT 202/202COV and MT 25/205COV message formats? | |
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| V. Transaction Monitoring | ||||||||||||||||||
| 29. | Does your institution have a monitoring program for unusual and potentially suspicious activity that covers fund transfers and monetary instruments such as travelers checks, money orders, etc.? | |
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| VI. AML Training | ||||||||||||||||||
| 30. | Does your institution provide AML training to relevant employees that includes:
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| 31. | Does your institution retain record of your training sessions including attendance records and relevant training materials used? | |
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| 32. | Does your institution communicate new AML related laws or changes to existing AML related policies or practices to relevant employees? | |
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| 33. | Does your institution employ third parties to carry out some of the functions of the institution? | |
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