PWC Kyc Anti Money Laundering Guide 2013 PDF

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Know Your Customer:

Quick Reference Guide
Anti-Money Laundering
Understanding global
KYC differences
January 2013
Launch
Know Your Customer: Quick Reference Guide

Understanding global KYC differences
Record-breaking fines issued by regulators worldwide, notably in Please rollover map to select your region then click to select country of choice
the US and UK, dominated the financial services landscape in 2012.
This looks set to continue in 2013 if regulators identify further failings
in firms compliance with money laundering, sanctions and tax
requirements. Cultural changes towards compliance-driven objectives
should be a key priority for financial services firms if they wish to
avoid their reputation being tarnished by similar scandals. Firms
operating on a global basis will also need to demonstrate a robust
compliance framework ensuring that each territory has sufficient
oversight and that Anti Money Laundering (AML) regulatory
requirements are being adhered to at both a local and global level.
In light of the above, we have developed a Know Your Customer
(KYC) quick reference guide which provides quick and easy access
to global AML and KYC information, to assist firms operating
internationally in mitigating their risk.
This years guide has been expanded to include additional new
countries and incorporates the main local AML requirements for
over 74 different countries.
The guide details many regulatory and other cultural issues which
need to be addressed when doing business across territories. Useful
links to Financial Action Task Force (FATF) reports and country
evaluations are also included. There are also questions on the topic
of reporting requirements within the various territories such as
whom to report suspicious activity to, reporting obligations and any
penalties for non compliance.
Information about whether local regulators support the use of the
risk based approach to AML; how to deal with Politically Exposed
Persons (PEPs) and whether doing business with shell banks is
prohibited can all be found in our guide.
From time to time, you may need expert advice from AML
specialists. Weve included details of the appropriate PwC AML
professionals in the countries featured. They would be happy to
discuss any AML issues you might have.

Record-breaking fines issued by regulators worldwide, notably in Click to return to main map
From time to time, you may need expert advice from AML Europe
specialists. Weve included details of the appropriate PwC AML Finland Netherlands
Austria Germany Isle ofHungary
Man Poland Switzerland
Slovakia
discuss any AML issues you might have. Belgium Gibraltar
France Italy Ireland Norway
Portugal Turkey
Spain
Bosnia & Herzegovina Greece Germany
Czech Republic JerseyIsle of Man Romania
Poland UK Sweden
Cyprus
Denmark GuernseyGibraltar Luxembourg
Italy RussiaPortugal Switzerland
FinlandRepublic
Czech Hungary Greece Netherlands
Jersey SpainRomania Turkey
France
Denmark Ireland Guernsey NorwayLuxembourg SwedenRussia UK

From time to time, you may need expert advice from AML Americas
specialists. Weve included details of the appropriate PwC AML Argentina Brazil Cayman Islands Jamaica Paraguay Uruguay
discuss any AML issues you might have. Bolivia Canada Colombia Mexico Peru USA

From time to time, you may need expert advice from AML Africa
specialists. Weve included details of the appropriate PwC AML Angola Cte dlvoire (Ivory Coast) Gabon Kenya Zambia
discuss any AML issues you might have. Cameroon Egypt Ghana South Africa

From time to time, you may need expert advice from AML Middle East
specialists. Weve included details of the appropriate PwC AML Bahrain Iraq Israel Jordan Lebanon Oman Qatar UAE
discuss any AML issues you might have.

From time to time, you may need expert advice from AML Asia/Pacific
specialists. Weve included details of the appropriate PwC AML
Austrailia
Australia India Malaysia Philippines Taiwan
discuss any AML issues you might have. China Indonesia New Zealand Singapore Thailand
Hong Kong Japan Pakistan South Korea Vietnam
Questions and Answers:
Know Your Customer quick reference guide
Country by country comparison of high level Know Your Customer and Anti-Money Laundering information
Zambia
Key contact: Nasir Ali Postal address: Stand No. 2374 Last updated:
Email: nasir.y.x.ali@zm.pwc.com Thabo Mbeki Road January 2013
Tel: +260 211 256471/2 P.O Box 30942, Lusaka, Zambia
General
Q1. In what year did the relevant AML laws and regulations become effective?
A1. 2001 (Prohibition & Prevention of Money Laundering Act), 2010 (Prohibition & Prevention of Money Laundering (Amendment) Act # 44 2004
(Bank of Zambia Anti-Money Laundering Directives) and the Financial Intelligence Centre Act 2010.
Q2. If the AML laws and/or regulations became effective in the last 2 years, what were the requirements of the previous AML regime?
A2. N/A.
Q3. Who is the regulator for AML controls for: (a) Banking; (b) Other financial Services; (c) Non financial sector (e.g. casinos, high value goods
etc.). Please include link to the regulator(s) website
A3. Bank of Zambia - http://www.boz.zm/

Pensions and Insurance Authority www.pia.org.zm
Q4. Is there any practical guidance provided to firms by public authorities regarding AML requirements, beyond the FATF recommendations and
local legislation? Please include link to website, where available.
A4. No.
Q5. Is there a requirement to retrospectively verify the identity of customers before the date the new AML regime was introduced?
A5. No.
Q6. Is a risk based approach approved by the local regulator(s)?
A6. Yes.
Q7. Has the country been the subject of a FATF (or FATF-style) Mutual Evaluation or IMF assessment exercise in the last three years? If yes,
please find a link to a relevant report (if publicly available).
A7. http://www.imf.org/external/pubs/ft/scr/2010/cr1017.pdf
Customer due diligence
Q8. Are there minimum transaction thresholds, under which customer due diligence is not required?
If Yes, what are the various thresholds in place?
A8. There are no minimum transaction thresholds, under which customer due diligence is not required.
.
This publication has been prepared for general guidance on matters of interest for the personal use of the reader, and does not constitute professional advice. You should not act upon the information
contained in this publication without obtaining specific professional advice. The application and impact of laws can vary widely based on the specific facts involved. No representation or warranty (express
or implied) is given as to the accuracy or completeness of the information contained in this publication, and, to the extent permitted by law, PricewaterhouseCoopers LLP, its members, employees and
2013 PwC. All rights reserved. Not for further distribution without the permission of PwC. PwC refers to the network of member firms of PricewaterhouseCoopers International Limited (PwCIL), or, as the
agents do not accept or assume any liability, responsibility or duty of care for any consequences of you or anyone else acting, or refraining to act, in reliance on the information contained in this
context requires,
publication or forindividual member
any decision basedfirms of the PwC network. Each member firm is a separate legal entity and does not act as agent of PwCIL or any other member firm. PwCIL does not provide any services
on it.
to clients. PwCIL is not responsible or liable for the acts or omissions of any of its member firms nor can it control the exercise of their professional judgment or bind them in any way. No member firm is
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member firm nor can it control to the network
exercise
PricewaterhouseCoopers International Limited, each of which is a separate and independent legal entity.
The Design Group 21383 (01/13)
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professional judgment or bind another member firm or PwCIL in any way.
Q9. What are the high level requirements for verification of customer identification information (individuals and legal entities)?
A9. Individuals:
A Zambian national has to present a national registration card or a valid passport or driving licence. In the case of a foreign national, a
national registration card and a valid passport (and where applicable, an issued visa).
Legal entities:
Verify the identity of the directors, beneficial owners and management i.e. obtain Certificate of Incorporation or equivalent and details of the
registered office/place of business; details of the nature of their business; the reason for the account being opened; indication of the
expected turnover; the source of funds and a copy of the last available accounts where applicable.
The Financial Intelligence Centre Act stipulates that:
A reporting entity shall, with respect to each customer obtain and verify the following:
a) For a natural person, the full name and address and date of birth and place of birth,
b) For a legal entity, the corporate name, the head office address, identities of directors, proof of incorporation or similar evidence of
legal status and legal form, provisions of governing the authority to bind the legal person, and such information as is necessary to
understand the ownership and the control of the legal person,
c) For legal arrangement, the name address of the trustees, the settler and the beneficiary of express trusts, and any other parties
with the authority to manage, vary or otherwise control the arrangement
d) In addition to the identity of a customer, the identity of any person acting on behalf of the customer, including evidence that such
person is properly authorised to act in that capacity,
e) Information on the intended purpose and nature of each business relationship; and
f) Sufficient information about the nature and business of the customer to permit the reporting entity to fulfil its obligations under the
Act.
Q10. Where copies of identification documentation are provided, what are the requirements around independent verification or authentication?
A10. Certification of relevant identification copies by a Commissioner of Oaths.
Q11. What are the high level requirements around beneficial ownership (identification and verification)?
A11. Regulated institutions should identify the beneficial owner of an account (regardless of whether it is a corporate body or trust opening the
account) and if it fails to ascertain the identity of the said owner or person, it should make a report to the AML Investigations Unit.
The Financial Intelligence Centre Act stipulates that a reporting entity shall identify the beneficial owner and shall take reasonable measures
to verify the identity of the beneficial owner unless the Minister prescribes the circumstances, such as the ownership of publicly held
corporations, in which such identification and verification is not necessary.
Q12. In what circumstances are reduced/simplified due diligence arrangements available?
A12. For regulated institutions, the circumstances are to be determined by the regulated institution and approved by Bank of Zambia.
Q13. In what circumstances are enhanced customer due diligence measures required?
A13. In the case of trusts and internet banking. Also in circumstances of suspicion as stated below:
a) suspicious customer behaviour;
b) suspicious customer identification circumstances;
c) suspicious cash transactions;
d) suspicious wire transfer transactions;
e) suspicious safe deposit area activity;
f) suspicious activity in credit transactions;
g) suspicious commercial account activity;
h) suspicious trade financing transactions;
i) suspicious investment activity; and
j) suspicious deposits.
.
publication or for any decision based on it.
2009 PricewaterhouseCoopers. All rights reserved. PricewaterhouseCoopers refers to the network of member firms of
Q14. In what circumstances is additional due diligence required for Politically Exposed Persons (PEPs)?
A14. The circumstances are to be determined by the regulated institution and approved by Bank of Zambia.
Q15. What enhanced due diligence must be performed for correspondent banking relationships (cross-border banking and similar relationships)?
A15. A financial institution shall require its foreign branches and majority owned subsidiaries to implement the requirements to the extent that the
domestic applicable laws of the host country so permit. Where the laws of the country in which its branch or majority owned subsidiary is
situated prevent compliance with the obligations stipulated, institutions must advise its supervisory authority, which may take such steps as
it believes to be appropriate to accomplish purposes of the Act.
Q16. Are relationships with shell banks specifically prohibited?
A16. Yes, the Financial Intelligence Centre Act stipulates that a shell bank shall not be established or permitted to operate in or through the
territory of Zambia.
Q17. In what circumstances is additional due diligence required for non face-to-face transactions and/or relationships?
A17. The standard due diligence procedure of identification and verification applies for non face-to-face transactions and/or relationships.
Financial Intelligence Centre Act states that where any business relationship or execution of transactions is made with a customer that is not
physically present, the following is required for purposes of identification:
a) Take adequate measures to address the specific risk of money laundering, financing of terrorism and any other serious offence;
b) Ensure that the due diligence conducted is no less effective than where the customer appears in person; and
c) Require additional documentary evidence or supplementary measures to verify or certify the documents supplied by the customer,
or confirmatory certification from financial institutions or other documentary evidence or measure may be prescribed.
Reporting
Q18. To whom are Suspicious Activity Reports (SARs) made? Please include a link to their website.
A18. Suspicious Activity reports are made to the Anti Money Laundering Investigations Unit and for financial institutions the Financial Intelligence
Centre
Q19. What was the volume of SARs made to the authorities in the most recent year? Please state the GDP for the equivalent year.
A19. Information on the volume of SARs is not publicly available.
Q20. Are there any obligations to report anything more than suspicious transactions e.g. unusual transactions, cash transactions above a certain
threshold, international wire transfers, other transactions etc.?
A20. No there is no obligation to report anything more than suspicious transactions please see response to Q13.
Financial institutions are obliged to report where there is suspicion or reasonable grounds to suspect that any property is the proceeds of
crime, or is related to or linked to, or is to be used for terrorism, terrorist acts or by terrorist organisations or persons who financed terrorism.
Q21. Are there any de-minimis thresholds below which transactions do not need to be reported?
A21. No
.
Q22. Are there any penalties for non compliance with reporting requirements e.g. tipping off?
A22. Any person who knows or suspects that an investigation into money laundering has been, is being or is about to be conducted, without
lawful authority, divulges that fact or information to another person, shall be guilty of an offence and shall be liable, upon conviction, to a fine
not exceeding one hundred and thirty-nine thousand penalty units (approximately ZMK25,020,000) or to imprisonment for a term not
exceeding five years or to both.
Financial Intelligence Centre act states that the penalties for tipping off upon convictions shall be liable to a fine not exceeding five hundred
thousand penalty units (approximately ZMK90,000,000) or to imprisonment for a period not exceeding five years, or to both.
A person who intentionally fails to submit a report to the Centre commits an offence and is liable, upon conviction to a fine not exceeding
seven hundred thousand penalty units (approx ZMK126,000,000) or to imprisonment for a period not exceeding seven years, or to both.
Q23. Are there any requirements (legal or regulatory) to use automated Suspicious Transaction monitoring technology?
A23. No
Q24. Is there a requirement to obtain authority to proceed with a current/ongoing transaction that is identified as suspicious?
A24. The regulated institution shall report to the AML Investigations Unit where the identity of the persons involved, the circumstances of any
business transaction or where any cash transaction, gives any officer or employee of the regulated institution reasonable grounds to believe
that a money laundering offence is being, has been or is about to be committed.
Per the Financial Intelligence Centre acts a financial institution shall refrain from carrying out a transaction which it suspects to be related
to the money laundering, financing of terrorism or any other serious offence.
Q25. Does the local legislation allow transactions to be monitored outside the jurisdiction?
A25. Although the local legislation does not specify this, one of the mandates of the Anti Money Laundering Investigations Unit is to cooperate
with law enforcement agencies and institutions in other jurisdictions responsible for investigation and prosecution of money laundering
offences.
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or implied) is given as to the accuracy or completeness has been contained
of the information prepared for general
in this guidance
publication, on to
and, matters of interest
the extent only,byand
permitted law,does not constitute professional
PricewaterhouseCoopers LLP, advice. You should
its members, not act
employees upon
and
agents do not accept or assume any liability, responsibility or duty
the information of care in
contained forthis
anypublication
consequences of you
without or anyone
obtaining else professional
specific acting, or refraining
advice.to
Noact, in reliance onorthe
representation information
warranty contained
(express in this
or implied) is given as
publication or for any decision based on it. to the accuracy or completeness of the information contained in this publication, and, to the extent permitted by law, PwC does do not accept or assume
PricewaterhouseCoopers International Limited, in thisofpublication

each which is a or for any and
separate decision based on
independent it. entity.
legal
any liability, responsibility or duty of care for any consequences of you or anyone else acting, or refraining to act, in reliance on the information contained
South Africa
Key contact: Roy Melnick Postal address: 2 Eglin Road Last updated:
Email: roy.melnick@za.pwc.com Sunninghill, 2157, South Africa January 2013
Tel: +27 11 797 4064
General
A1. AML laws

The Prevention of Organised Crime Act No. 121 of 1998. The Financial Intelligence Centre Act, 38 of 2001 (FICA) was enacted in 2001.
The Financial Intelligence Centre Amendment Act, 2008 (Act No. 11 of 2008) was released in August 2008 and became effective on 1
December 2010. Section 28 and Section 51 of FICA the cash threshold reporting provisions - came into operation in October 2010.
Regulations
The Money Laundering and Terrorist Financing Control regulations were published in December 2002 and have been amended on various
occasions, the most recent being in November 2010.
A2. The main amendments to FICA do not detract from the original AML requirements but rather clarify areas in the law. The purpose of the
amendments are inter alia to clarify the roles and responsibilities of supervisory bodies; authorise the Financial Intelligence Centre and
supervisory bodies to conduct inspections; to provide for administrative sanctions and to make further provision for offences.
A3. The Financial Intelligence Centre (www.fic.gov.za) fulfils an overarching regulatory role for combating money laundering and terrorist
financing. Industry regulators and supervisory bodies provide oversight within the various industries
a) South African Reserve Bank - www.resbank.co.za/
b) Financial Services Board - www.fsb.co.za/
c) Casinos - National Gambling Board - www.ngb.org.za/
Real Estate - Estate Agency Affairs Board - www.eaab.org.za/
Attorneys - Law Society - www.lssa.org.za/
A4. The Financial Intelligence Centre Act has issued various guidance notes with regards to AML requirements. These can be at
https://www.fic.gov.za/SiteContent/ContentPage.aspx?id=15
A5. Yes - banks and other accountable institutions were required to retrospectively identify and verify the identity and other information of all
clients that held accounts with them at the time that the law became operational. An accountable institution that had an established business
relationship with a client before the FIC Act took effect, may not conclude a transaction in the course of that business relationship, unless it
has taken the prescribed steps to establish and verify the identity of the client.
A6. Yes although the FIC Act, 38 of 2001 and the regulations do not expressly make reference to a risk-based approach, it is covered in
Guidance Note 1 issued by the FIC in April 2004. Accountable institutions are expected to apply a risk-based approach inter alia in respect
of customer relationships.
.
context requires,
on it.
exercise
of member
member of

clients that held accounts with them at the time that the law became operational. An accountable institution that had an established business
relationship with a client before the FIC Act took effect, may not conclude a transaction in the course of that business relationship, unless it
has taken the prescribed steps to establish and verify the identity of the client.
Questions
Q6. Is a risk and Answers:
based approach approved by the local regulator(s)?
Know
A6. Your Customer quick reference guide
Yes although the FIC Act, 38 of 2001 and the regulations do not expressly make reference to a risk-based approach, it is covered in
Guidance Note 1 issued by the FIC in April 2004. Accountable institutions are expected to apply a risk-based approach inter alia in respect
of customer relationships.
.
A7.
This publicationThe
has last
been Mutual
prepared Evaluation conducted
for general guidance onofSouth
on matters interestAfrica was finalised
for the personal use of thein 2008.
reader, andThe
doesapplicable
not constitutereport wasadvice.
professional published on the
You should 2 ndupon
not act of March 2008.
the information
http://www.fatf-gafi.org/topics/mutualevaluations/documents/mutualevaluationofsouthafrica.html
A8. No - Due diligence is always required for all client relationships and single transactions, irrespective of the value involved. However the law
does make provision for certain exemptions where a reduced level of due diligence is permitted. These exemptions form part of the FIC Act
regulations and affect various industries.
A9. Individuals (SA residents) - an accountable institution must verify the full name, date of birth and identity number of a natural person to an
identification document of that person. The residential address must be compared to information that can be used for verification purposes
(e.g. a utility bill stating the residential address of the individual).
Legal entities the registered name, registration number, registered address, trading name and the address of the entity as well as the
identity of the manager of the company; and each authorised person. The FIC Act regulations contain the detail of other requirements
pertaining to these as well as other persons/entities (foreign nationals, agents, foreign companies, trusts, partnerships and close
corporations.)
A10. Although the FIC Act stipulates that a record must be kept of the identity document, it does not specify the requirements pertaining to
authentication. In terms of the guidance notes and best practices, it would be sufficient to review the original identity document and to obtain
a copy of a document which is either certified by a Commissioner of Oaths; or where the original has been sighted by an employee of the
accountable institution, and an indication of such is made on the copy.
Guidance is also provided on non face-to-face verification by the FIC. Where non face-to-face verification is accepted as a means, the
verification methods used must be as effective as those that are applied to customers who are available for an interview.
A11. The FIC Act stipulates, inter alia, that the identity of the client, or if the client is acting on behalf of another person or if another person is
acting on behalf of the client, must be established and verified.
The regulations have put in place measures to determine beneficial owners in respect of entities. For example, the particulars of every
member and every representative of a close corporation must be obtained. In respect of a company the particulars of its manager and
representatives must be provided as well as the particulars of its major shareholders who are able to exercise more than 25% of the votes at
a general meeting of the company. In respect of trusts, the identity of the founder, beneficiaries and trustees must be established.
A12. Depending on the risk profile, the level of due diligence is simplified for low risk clients or in respect of existing clients who are applying for
different products. The exemptions, which form part of the FIC Act regulations, contain detail of the circumstances under which reduced or
simplified due diligence may be applied. Simplified due diligence applies inter alia to companies listed on approved stock exchanges
(exemption 6) and banking products issued to customers subject to particular conditions and thresholds (exemption 17).
A13. The FICA Guidance notes state that accountable institutions should follow a risk-based approach to customer due-diligence. Clients are
given a risk-rating based on various risk factors. High-risk client types and high risk transactions and services warrant enhanced due
diligence procedures. In respect of PEPs, non-face-to-face verification, correspondent banks, money service businesses, intermediary and
employee accounts, enhanced due-diligence is recommended.
.
A14. Guidance from the FIC defining PEPs stipulates that the bank should conduct enhanced due diligence specifically on PEPs, persons acting
on their behalf as well as families and closely associated persons to the PEP, as they are considered high risk. The Wolfsberg principles as
well as the FATF recommendations are referred to for additional guidance on how to recognise and deal with a PEP.
In addition to performing customer due diligence measures, banks should put in place appropriate risk management systems to determine
whether a customer, a potential customer or the beneficial owner is a PEP.
A15. The FIC guidance notes provide that banks should pay particular attention when continuing relationships with correspondent banks located
in jurisdictions that have poor KYC standards or have been identified by FATF as being non co-operative. The Wolfsberg principles are
referred to which set out the following risk indicators that a Bank shall consider, to ascertain the level of due diligence it will undertake,
namely the correspondent banking clients domicile, ownership, management structures and business and customer base.
A16. The FIC guidance notes provide that banks should refuse to enter into or continue a correspondent banking relationship with a bank
incorporated in a jurisdiction in which it has no physical presence and which is unaffiliated with a regulated financial group (i.e. shell banks).
A17. The FICA Regulations and guidance notes provide for instances in which client information is obtained in a non face-to-face situation. In
such cases, banks must take reasonable steps to confirm the existence of the client and to verify the identity of the natural person
involved, for example, receipt of faxes. In accepting business from non face-to-face customers banks should apply customer identification
procedures to non face-to-face customers that are as effective as those that were applied to customers who were available for interview;
and there must be specific and adequate measures to mitigate the higher risk. Decisions concerning the additional steps to be taken in
cases of a non face-to-face situation should be based on a banks risk framework.
Reporting
A18. Suspicious Activity Reports are submitted to the Financial Intelligence Centre (FIC).
https://www.fic.gov.za/Secure/Reports.aspx
A19. Volume of SARs:

2011 53,506 STRs (FIC Annual report 2011/ 2012)
GDP (in current prices):

2011 USD 408.2 billion (Source: data.worldbank.org* )
This results in a ratio of 1 SAR for every USD7.6 million of GDP.
A20. Yes, the Financial Intelligence Centre Act has additional reporting requirements as contained within its Regulations. These are:
a) Regulation 22A: Information to be reported concerning property associated with terrorist and related activities.
b) Regulation 22B: Cash threshold reporting
* GDP at purchaser's prices is the sum of gross value added by all resident producers in the economy plus any product taxes and minus any subsidies not included in the value of the products. It is
calculated without making deductions for depreciation of fabricated assets or for depletion and degradation of natural resources. Data are in current U.S. dollars. Dollar figures for GDP are converted from
Q21. Are there
domestic currencies any year
using single de-minimis thresholds
official exchange below
rates. For which transactions
a few countries where the officialdo not need
exchange rate to benotreported?
does reflect the rate effectively applied to actual foreign exchange transactions, an
alternative conversion factor is used.
.
A21.
This publicationTransactions below
has been prepared ZAR24,999
for general need
guidance on notofbe
matters reported.
interest for the personal use of the reader, and does not constitute professional advice. You should not act upon the information
A22. Yes, a person found guilty of such an offence may be fined ZAR100 million or imprisoned for up to 15 years.
A17. The FICA Regulations and guidance notes provide for instances in which client information is obtained in a non face-to-face situation. In
A20. Yes, cases,
such the Financial
banks Intelligence Centre Act steps
must take reasonable has additional reporting
to confirm requirements
the existence as contained
of the client withinthe
and to verify itsidentity
Regulations.
of the These
naturalare:
person
a) for
involved, Regulation
example,22A: Information
receipt of faxes.toInbe reportedbusiness
accepting concerning
fromproperty associatedcustomers
non face-to-face with terrorist andshould
banks relatedapply
activities.
customer identification
b) Regulation
procedures 22B: Cashcustomers
to non face-to-face threshold reporting
that are as effective as those that were applied to customers who were available for interview;
and there must be specific and adequate measures to mitigate the higher risk. Decisions concerning the additional steps to be taken in
cases of a non face-to-face situation should be based on a banks risk framework.
Know
Q21. Your Customer quick reference guide
Are there any de-minimis thresholds below which transactions do not need to be reported?
A21. byTransactions below ZAR24,999 need not be reported.

Country country comparison of high level Know Your Customer and Anti-Money Laundering information
Reporting
A22. Yes, a person found guilty of such an offence may be fined ZAR100 million or imprisoned for up to 15 years.
A18. Suspicious Activity Reports are submitted to the Financial Intelligence Centre (FIC).
https://www.fic.gov.za/Secure/Reports.aspx
A23. No.
2011 53,506 STRs (FIC Annual report 2011/ 2012)
Q24. Is there
GDP (in a requirement
current prices):to obtain authority to proceed with a current/ongoing transaction that is identified as suspicious?
2011 USD 408.2 billion (Source: data.worldbank.org* )
A24. Once a suspicious transaction has been reported, section 33 of the Financial Intelligence Centre Act allows an accountable institution to
continue
This with
results in the relationship
a ratio of 1 SARuntil directed
for every otherwise
USD7.6 byof
million the Financial Intelligence Centre. This is confirmed by Guidance Note 4 on
GDP.
Suspicious Transaction Reporting, issued by the Financial Intelligence Centre on the 14 th of March 2008.
Q25. Does the local
threshold, legislation
international allow
wire transactions
transfers, to be monitored
other transactions etc.?outside the jurisdiction?
A25. No. South African law only applies within the borders of the country.
domestic currencies using single year official exchange rates. For a few countries where the official exchange rate does not reflect the rate effectively applied to actual foreign exchange transactions, an
.
.
www.pwc.com.
This publication has been prepared for general guidance on matters of interest only, and does not constitute professional advice. You should not act upon
the information contained in this publication without obtaining specific professional advice. No representation or warranty (express or implied) is given as
to the accuracy or completeness of the information contained in this publication, and, to the extent permitted by law, PwC does do not accept or assume
in this publication or for any decision based on it.
Kenya
Key contact: Martin Whitehead Postal address: Last updated:
Email: martin.whitehead@ke.pwc.com Rahimtulla Tower, 7th Floor, Upper Hill Road, January 2013
Tel: +254 733 333207 Nairobi, Kenya
General
A1. 2010. The Proceeds of Crime and Anti-Money Laundering Act 2009 was enacted on 11 December 2009, assented on 31 December 2009
and its commencement date was on 28 June 2010.
A2. There was no AML regime per se in existence previously. However, the 1994 Narcotic Drugs and Psychotropic Substances Control Act
prohibits concealing or transferring the proceeds of drug trafficking.
A3. The Money Laundering Act provides for a Financial Reporting Center (FRC). The FRC was formally operationalised in April 2012. The FRC
is empowered to develop regulations on Anti-Money Laundering and to provide guidance to support the implementation of the Proceeds of
Crime and Anti-Money Laundering Act. The FRC has extensive functions and power including receiving and analysis of reports of unusual
or suspicious transactions made by reporting institutions. The FRC is also empowered to develop regulations on Anti-Money Laundering
and to provide guidance to support the implementation of The Proceeds of Crime and Anti-Money Laundering Act. This regulator does not
yet have a website.
A4. Yes. The Central Bank of Kenya has on occasions provided guidance notes regarding AML requirements.
www.centralbank.go.ke
A5. No.
A6. No.
A7. No. The country has not been subject of a FATF Mutual Evaluation or IMF assessment exercise in the last three years. However, Kenya is a
member of the Eastern and Southern Africa Anti-Money Laundering Group (ESAAMLG) and underwent a first mutual evaluation conducted
by the ESAAMLG in September 2011. The report can be found at the following link:
http://www.esaamlg.org/userfiles/Kenya_Mutual_Evaluation_Detail_Report%282%29.pdf

.
agents
2013 PwC.
do notAllaccept
rights or
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assumeNot
anyfor furtherresponsibility
liability, distribution without
or duty the permission
of care for any of PwC. PwC of
consequences refers
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orthe network
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information contained in this or, as the
context requires,
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member firm nor can it control to the
network
exercise of member
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Questions
A7. No. Theand
country Answers:
has not been subject of a FATF Mutual Evaluation or IMF assessment exercise in the last three years. However, Kenya is a

member of the Eastern and Southern Africa Anti-Money Laundering Group (ESAAMLG) and underwent a first mutual evaluation conducted
by the ESAAMLG in September 2011. The report can be found at the following link:
http://www.esaamlg.org/userfiles/Kenya_Mutual_Evaluation_Detail_Report%282%29.pdf

.
This publicationArehasthere
been prepared
minimum for general guidancethresholds,
transaction on matters of interest
underfor the personal
which customeruse of due
the reader, and does
diligence not constitute
is not required?professional advice. You should not act upon the information
Q8.
If Yes,
or implied) is given as towhat are the
the accuracy or various thresholds
completeness in place?
of the information contained in this publication, and, to the extent permitted by law, PricewaterhouseCoopers LLP, its members, employees and
A8. Yes - for telegraphic transfers and travellers cheques. A foreign exchange bureau should not sell foreign currency or travellers cheques in
excess orInternational
PricewaterhouseCoopers equal to Limited,
the equivalent of isUSD10,000
each of which a separate andper customer
independent legalper day without seeing
and recording a valid identification document.
entity.
A9. Individuals:
a) an official record such as passport, birth certificate, identity card or driving licence;
b) address verified by a referee or utility bill;
c) source of income; and
d) written confirmation from the customers previous bank attesting to their identity and account relationship history (bank referee).
Corporates / Firms:
a) Certificate of Registration, Certificate of Incorporation, Partnership Deed, Memorandum and Articles of Association;
b) Board Resolution stating authority to open accounts and designating persons having signatory authority;
c) identity and address of the chairman, managing director, or the general partner and at least one limited partner for partnerships,
or the principal owner for sole traders;
d) audited financial statements for corporations; and
e) where applicable, written confirmation from the customer's previous bank.
A10. Documents must be certified by suitable third parties and confirmation from the previous bank obtained where possible. Suitable third
parties include advocates, notaries public, commissioners of oath, judges, magistrates and certain government officials.
A11. Local guidance requires institutions to have full disclosure of beneficial owners or controlling persons behind nominee accounts.
A12. None stated in local regulations or guidance.
A15. As with face-to-face verification, the procedures to check identity must ensure that a person bearing the name of the applicant exists and
lives at the address provided; and the applicant is that person he claims he is.
Independent means of verifying these details includes requesting sight of a recent utility bill, local authority tax bill or institution statement
(care should be taken to check that the documents offered are originals in order to guard against forged or counterfeit documents,);
checking a local telephone directory (for businesses); making telephone contact with the applicant on an independently verified home or
business number; verifying salary details appearing on a recent bank account statement; or with the customers consent, calling their
employers personnel department to confirm employment etc.
.
Q16. Are
contained in this relationships
publication with shell
without obtaining banks
specific specifically
professional prohibited?
advice. The application and impact of laws can vary widely based on the specific facts involved. No representation or warranty (express
A16. Yes.
Know
Are relationships with shell banks specifically prohibited?
A16. by
Country Yes.
country comparison of high level Know Your Customer and Anti-Money Laundering information
A17. Local guidance requires the following due diligence: requesting sight of a recent utility bill, local authority tax bill, institution statement or
checking a local telephone directory (for businesses). In addition, satisfactory evidence of personal identity can be obtained by a number of
means, including telephone contact with the applicant on an independently verified home or business number, employers personnel
department confirming employment by verbal confirmation on a listed number (with the customer's consent), and salary details appearing on
a recent bank or building society statement.
Reporting
A18. The Act requires that SARs are made to the Financial Reporting Center. However this Center is yet to be set up, therefore all SARs are to
be made to the Central Bank of Kenya. www.centralbank.go.ke
A20. The Act requires monitoring on an ongoing basis all complex, unusual, suspicious, large or other transactions, and upon suspicion, it should
be reported accordingly.
A21. No.
A22. Tipping off is considered to be an offence under the Act, however the applicable penalty is not stipulated.
A23. No.
A24. No. However, the reporting institution is required to keep all records relating to that transaction and ensure that its reporting obligations
under the Act are discharged.
A25. While local legislation does not allow transactions to be monitored outside the jurisdiction per se, the Act provides for international
assistance in investigations and proceedings relating to money laundering.
.
www.pwc.com.
Ghana
Key contact: Felix Addo Postal address: Last updated:
Email: felix.addo@gh.pwc.com No 12 Airport City, UNA Home, 3rd Floor, January 2013
Tel: +233-21- 761500, 761614 PMB CT42, Cantonments, Accra, Ghana
General
A1. 2008. The Anti-Money Laundering Act of 2008 (Act 749), and the Anti-Money Laundering Regulations 2008 (LI 1925).
A2. Banks were to comply with the Bank of Ghana and/or parent bank KYC policies/procedures. No financial intelligence centre reporting
requirements. Bank of Ghana Supervision Department (and also Security agencies and Serious Fraud Office) played the quasi-role of a
centre investigating 'suspicious' transactions.
A3. Financial Intelligence Centre (website not available).
A4. Yes (website not available).
A5. No however, banks are encouraged to ensure that due diligence on customers is a continuous exercise.
A6. Yes.
A7. The assessment body GAIBA performed an assessment in 2009 (Source: FATF website).
A8. Yes equivalent of USD10,000.
.
context requires,
any decision basedfirms
on of
it. the PwC network. Each member firm is a separate legal entity and does not act as agent of PwCIL or any other member firm. PwCIL does not provide any services
of any other refersthe
exercise
of member
member of

A9. Individuals: Information required for individuals includes: legal name and other names, location of client, telephone, fax numbers, mailing
address, date and place of birth, nationality, hometown, occupation, position held and employer's name, identity documents, nature of the
business relationship and signature.
Legal entities: They require a registered name, location address, head office, mailing address, contact phone and fax numbers, original or
certified copy of regulations, certificate of business registration and commencement of business, copy of latest auditor's report and
accounts, annual report filed with the Registrar General and names, location and mailing addresses of directors.
A10. Identity shall be verified whenever a business relationship is to be established, on account opening or during one-off transaction or when
series of linked transactions take place.
A11. When one person is acting on behalf of another, the obligation is to obtain sufficient evidence of the identities of the two persons involved. In
consortium lending, the lead manager/agent shall supply a confirmation letter as evidence that he has obtained the required identity.
A12. None.
A13. Enhanced customer due diligence is required when dealing with Politically Exposed Persons ('PEPs').
A14. Additional due diligence is required for PEPs. Senior Management approval must be sought before establishing a relationship with such a
person. It is also a requirement to establish the PEPs source of wealth/source of funds and the beneficial owners.
A15. If the broker or other introducer is a regulated person or institution (including an overseas branch or subsidiary) from a country with
equivalent legislation and financial sector procedures, and the broker or introducer is subject to anti-money laundering rules or regulations,
then a written assurance can be taken from the broker that he/she has obtained and recorded evidence of identity of any principal and
underlying beneficial owner that is introduced.
A16. No.
A17. The specific requirements are in process of being formalised by the Bank of Ghana.
.
Reporting
A18. Financial Intelligence Centre (website not available).
A20. Yes - reporting should not be limited to Suspicious Transaction Reports (STRs) alone.
A21. No.
A22. Yes.
A23. No.
A24. Yes.
A25. No.
. PwC helps organisations and individuals create the value theyre looking for. Were a network of firms in 158 countries with more than 180,000
This publication has been prepared for general people
guidance who
on are committed
matters to delivering
of interest quality in
for the personal useassurance, tax and
of the reader, andadvisory
does notservices.
constituteTell us what matters
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www.pwc.com.
or implied) is given as to the accuracy or completeness of the information
This publication has been contained
prepared for in this publication,
general guidance and,
on to the extent
matters permitted
of interest only,byand
law,does
PricewaterhouseCoopers LLP, advice.
not constitute professional its members, employees
You should not actand
upon
contained forthis
anypublication
consequences of you
without or anyone
advice.toNoact, in reliance onorthe
warranty contained
(express in thisis given as
or implied)
PricewaterhouseCoopers International Limited, in

any liability,
2009 PricewaterhouseCoopers. All rights reserved. responsibility or duty of
PricewaterhouseCoopers
thisofpublication
separate decision
caretofor
refers
based on
independent
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Gabon
Key contact: Douty Fadiga Postal address: P.O.Box 5689 Douala, Last updated:
Email: d.fadiga@cm.pwc.com Cameroon January 2013
Tel: +237 77 93 40 70
General
A1. AML law and regulations became effective in 2005 and are only applicable for banks.
A2. N/A
etc.). Please include a link to the regulator(s) website
A3. a) Banking Commission. www.beac.int

b) None.
c) None.
A4. No.
A5. Yes - an update of the customer database is required.
A6. No There is no risk based approach approved by the local regulator.
A7. Yes - the country has been subjected to a FATF evaluation, but the report is not publicly available.
A8. No - there are no minimum transaction thresholds under which customer due diligence is not required.
context requires, individual member firms of the PwC network. Each member firm is a separate legal entity and does not act as agent of PwCIL or any other member firm. PwCIL does not provide any services
responsible or liable for the acts or omissions of any other member firm nor can it control the exercise of another member firms professional judgment or bind another member firm or PwCIL in any way.
Are there minimum transaction thresholds, under which customer due diligence is not required?
Q8.
A8. by No - there are no minimum transaction thresholds under which customer due diligence is not required.
A9. The requirements are:

a) verification of the identity and address of the customer by reference to official identity papers;
b) for legal entities, the verification of legal documents and legal representatives is required;
c) public officials require a heightened scrutiny;
d) the bank must collect information to cover the following: anticipated account activity, source of wealth and sources of funds.
A10. None in the practice. Copies of identification documentation are only made by the bank after a visual check. Independent verification is not
required.

a) Obtain information on the beneficial owner;
b) Verification of the identification and the address of the professional intermediary.
A12. Customer due diligence arrangements are reduced for low value transactions.
A13. Customer due diligence is enhanced for unusual or suspicious activities/transactions.
A14. For a PEP, the banks senior management may give authorisation before an account opening. The transactions in their accounts require
heightened scrutiny.
A15. Banks must acquire information on the compliance of their correspondent with Anti Money Laundering regulation. The relationship must not
be established if the correspondent is not compliant with AML regulation.
A16. Yes.
A17. For a non face-to-face relationship, a bank must consider the need to perform independent verification.
Reporting
A18. The suspicious activity report is addressed to the National Agency for financial investigation (ANIF).
Reporting
A18. The suspicious activity report is addressed to the National Agency for financial investigation (ANIF).
A20. There is an obligation to report on transaction where the identity of the beneficiary or the originator is suspicious.
A21. No.
A22. No.
A23. No.
A24. No.
A25. Yes.
www.pwc.com.
Egypt
Key contact: Nabil Diab Postal address: Last updated:
Email: nabil.diab@eg.pwc.com Plot no 211, Second Sector, City Center, New January 2013
Tel: +1 (0) 876 932 8335 Cairo 11835, Egypt,
PO Box 170 New Cairo
General
A1. 2002.
A2. N/A.
A3. a)
b)
Banking: CBE (Central Bank of Egypt): www.cbe.org.eg/
Other financial Services: It depends on the nature of the financial services (e.g. Insurance companies are regulated by the EISA
(Egyptian Insurance Supervisory Authority). However, all of the non-banking financial services providers are governed and
regulated by the EFSA (Egyptian Financial Supervisory Authority);
c) Non financial sector: Governed by the Anti Money Laundering Law- Law # 80 for year 2002.
A4. There is the only the Anti Money Laundering Law - Law # 80 for year 2002.
A5. Yes.
A6. No.
A7. No.
.
2013 PwC.
agents do notAll rightsor
accept reserved.
assumeNot
consequences refers
you toor the network
or refraining to act, in reliance on the International Limited (PwCIL),
context requires,
on it.
network
exercise of member
member of

A6. No.
Q7. please find a link to a relevant report (if publicly available).

Has the country been the subject of a FATF (or FATF-style) Mutual Evaluation or IMF assessment exercise in the last three years? If yes,
Know
No.
. A8. No.
Q9.
publication or for any decision
What are thebased
highonlevel
it. requirements for verification of customer identification information (individuals and legal entities)?
A9. Individuals: should obtain name, address and date of birth, ideally from government-issued documents such as government identification ,
passport and weapon licence that includes the customer's full name and photograph, and either address or date of birth.
Corporates: should obtain full name, Commercial Register copy, business address, and additionally for private companies, names of all
directors and beneficial owners. This should be clearly noted in the Commercial Register of the company and also show the authorised
signatories of the company. If the company is regulated (e.g. insurance or capital markets) it should provide confirmation of the companys
listing on the regulated market or a copy of the companys Certificate of Incorporation.
A10. Copies of documents should be authenticated by a banks' senior staff after reviewing and verifying the original documents. Only copies
certified and stamped by governmental bodies/authorities can be relied upon by banks. Authenticated copies from attorneys or other third
parties are not accepted unless original copies are obtained.
A11. Each natural or legal person having a real interest in any of the activities of financial institutions, even if the transaction is conducted via
another natural or legal person acting as a trustee, a proxy or under any other capacity, should provide documentation to verify identity.
A14. Yes - the law states that financial institutions and the other entities shall take special customer due diligence measures when dealing with
customers, those who act on their behalf and the real beneficiary, who are identified as PEPs.
A16. No.
.
Reporting
A18. SARs are made directly to regulators as specified in Q3 above.
A20. No.
A21. No.
A22. Yes - as stated in the Egyptian AML Law (Anti Money Laundering Law - Law # 80 for year 2002).
A23. No.
A24. Yes - as stated in the Egyptian AML Law (Anti Money Laundering Law - Law # 80 for year 2002).
A25. Yes.
.
www.pwc.com.
This publication
in this guidance
publication, on to
PricewaterhouseCoopers advice.
LLP, its You should
members, not act
employees upon
and
the information of care for
contained anypublication
in this consequences of you
without or anyone
obtaining else acting,
specific or refraining
professional advice.toNo
act, in reliance onorthe
warranty contained
or implied)
any liability,
2009 PricewaterhouseCoopers. All rights reserved. responsibility or duty refers
in thisofpublication
PricewaterhouseCoopers International Limited, each which is a or for anyand
separate
of caretofor
decision
theany
based on
independent
consequences
network of member
it. entity.
legal
of firms
you or

of anyone else acting, or refraining to act, in reliance on the information contained
Cte dIvoire (Ivory Coast)

Tel: +237 77 93 40 70
General
A2. N/A.
A3. a) Banking Commission. www.bceao.int

b) None
c) None
A4. No.
A6. No there is no risk based approach approved by the local regulator.
A7. Yes - the country has been subjected to a FATF evaluation, but the report is not publicly available.
.
2013 PwC.
accept reserved.
assumeNot
consequences refers
context requires,
on it.
network
exercise of member
of another firms of
member

firms professional judgment or bind another member firm or PwCIL in any way.

a) verification of the identity and address of the customer by reference to official identity papers;
A10. None in the practice. Copies of identification documentation are only made by the bank after a visual check. Independent verification is not
required.

a) Obtain information on the beneficial owner;
A14. For a PEP, the banks senior management may give authorisation before an account opening. The transactions in their accounts require
A15. Banks must acquire information on the compliance of their correspondent with Anti Money laundering regulation. The relationship must not
A16. Yes.
Reporting
A18. National Centre for Processing of Financial Information (CENTIF).

. www.centif.ci
Q19. What
publication or for was the
any decision volume
based on it. of SARs made to the authorities in the most recent year? Please state the GDP for the equivalent year.
A19. Volume of International
SARs: Limited, each of which is a separate and independent legal entity.

2010 56 SARs

2010 56 SARs
Questions and prices):

GDP (in current Answers: *

2010 USD22,780 million (Source: data.worldbank.org )
This results
National in a ratio
Centre of 1 SAR for
for Processing of every USD406.8
Financial million
Information of GDP.
(CENTIF).
A18. www.centif.ci
A20. There
Volumeis an obligation to report on transactions where the identity of the beneficiary or the originator is suspicious.
of SARs:
A19. 2010 56 SARs
GDP
Are (in current
there prices): thresholds below which transactions do not need to be reported?
any de-minimis
Q21. 2010 USD22,780 million (Source: data.worldbank.org * )
A21. No.
Q20. Are there

Are there any
anypenalties
obligations
fortonon
report anythingwith
compliance more than suspicious
reporting transactions
requirements e.g. off?
e.g. tipping unusual transactions, cash transactions above a certain
Q22. threshold, international wire transfers, other transactions etc.?
A22. No.
A20. There is an obligation to report on transactions where the identity of the beneficiary or the originator is suspicious.
A23. No.
A21. No.
A24. No.
A22. No.
A25. Yes.
A23. No.
A24. No.
A25. Yes.
.
.
publication or for any decision based on it. PwC helps organisations and individuals create the value theyre looking for. Were a network of firms in 158 countries with more than 180,000
peoplePricewaterhouseCoopers
2009 PricewaterhouseCoopers. All rights reserved. who are committed to delivering
PricewaterhouseCoopers International Limited, www.pwc.com.
quality
refers to in assurance,
the network
each of which is a separate and independent legal entity.
tax and
of member advisory
firms of

services. Tell us what matters to you and find out more by visiting us at
Cameroon
Tel: +237 77 93 40 70
General
A2. N/A
A3. a) The Banking Commission. www.beac.int

b) None
c) None
A4. No
A6. No there is no risk based approach approved by the local regulator.
A7. Yes the country has been subjected to a FATF evaluation, but the report is not publicly available.
.
agents
2013 PwC.
do notAll rightsor
accept reserved.
assumeNot
consequences refers
you to
or the network
anyone elseof member
acting, firms of PricewaterhouseCoopers
context requires,
on it.
network
exercise of member
member of

A9. a) verification of the identity and address of the customer by reference to official identity papers;
A10. None, in practice. Copies of identification documentation are only made by the bank after a visual check. An independent verification is not
required.
A11. a) Obtain information on the beneficial owner;

A14. For a PEP, the banks senior management must give authorisation before an account opening. The transactions in their accounts require
A15. Banks must acquire information on the compliance of their correspondent with Anti Money laundering regulation. The relationship must not
A16. Yes.
Reporting
A18. National Agency for financial investigation (ANIF).

www.anif.cm
.
contained in this publication
What was without obtaining
the volume ofspecific
SARsprofessional
made toadvice. The application
the authorities in and
theimpact
mostofrecent
laws can vary widely
year? based
Please on thethe
state specific
GDP facts
forinvolved. No representation
the equivalent year. or warranty (express
Q19.
2010 124 SARs
2010 USD22,394 million (Source: data.worldbank.org * )

2010 124 SARs
Know
A18.
Your Customer quick reference guide
National Agency for financial investigation (ANIF).
www.anif.cm
Q20. Are there

What wasanytheobligations to report
volume of SARs anything
made to the more than suspicious
authorities in the mosttransactions
recent year?e.g. unusual
Please statetransactions,
the GDP forcash transactions
the equivalent above a certain
year.

2010 is124
There SARs
an obligation to report on transactions where the identity of the beneficiary or the originator is suspicious.
A20.
Q21. Are there any de minimis thresholds below which transactions do not need to be reported?
A21. No.
A20. There is an obligation to report on transactions where the identity of the beneficiary or the originator is suspicious.
A22. No.
Q23.
Q21. Are
Are there
there any
any requirements (legal or regulatory)
de minimis thresholds below which totransactions
use automated Suspicious
do not need to Transaction
be reported?monitoring technology?
A23.
A21. No.
No.
Q24.
Q22. Is there
Are a requirement
there any penaltiestofor
obtain
non authority
complianceto proceed with arequirements
with reporting current/ongoing
e.g.transaction
tipping off?that is identified as suspicious?
A24.
A22. No.
No.
Q23. Are there

Does any requirements
the local (legal
legislation allow or regulatory)
transactions to betomonitored
use automated
outsideSuspicious Transaction monitoring technology?
the jurisdiction?
Q25.
A23. No.
Yes.
A25.
A24. No.
A25. Yes.
.
.
2009 PricewaterhouseCoopers. All rights reserved.
PricewaterhouseCoopers International Limited, each
refers to
who are committed to delivering the network
quality of member
in assurance,
of which is a separate and independent legal entity.
www.pwc.com.
firms
tax and of
advisory

Angola
Key contact: Manuel Luz Postal address: Presidente Business Center Last updated:
Email: manuel.luz@pt.pwc.com Largo 4 de Fevereiro n.3, 1 andar- Sala 137 January 2013
Tel: +351 21 359 9304 Luanda ; Angola
General
A1. 2010. Law n. 12/10 was issued on 9/7/2010 and Aviso N 22/2012
A2. N/A
A3. The regulator for AML controls are:

a) Banco Nacional de Angola - www.bna.ao
b) Direco Nacional de Investigao e Inspeco das Actividades Econmicas do Comando Geral da Policia Nacional -
http://www.policiaeconomica.gv.ao/
A4. No.
A5. Law n. 12/10 does not make any reference to requirements to retrospectively verify of the identity of customers before the date the new
AML regime was introduced. This may be clarified in Regulation expected to be issued in the near future.
A6. Law n. 12/10, provides that, in compliance with identification and diligence requirements, financial institutions can adapt the nature and
scope of verification and diligence procedures, taking into account the risk associated with the type of customer, the business relationship,
the product, the type of transaction and the origin or the purpose of the funds.
A7. Angola has not been the subject of a FATF Mutual Evaluation. However, in February 2012 and in June 2012, FATF published a Global
AML/ CFT Compliance publication where Angolas AML regime is briefly analysed. The links to these publications are http://www.fatf-
gafi.org/countries/s-t/turkmenistan/documents/improvingglobalamlcftcomplianceon-goingprocess-16february2012.html (February 2012)
http://www.fatf-gafi.org/countries/a-c/angola/documents/improvingglobalamlcftcomplianceon-goingprocess-22june2012.html (June 2012).
The last IMF Country Report was published in May 2012. The report is the sixth country review under the stand-by agreement. The reports
link is http://www.imf.org/external/pubs/cat/longres.aspx?sk=25888.0
The country page (Angola and IMF) is http://www.imf.org/external/country/ago/index.htm.

.
agents
2013 PwC.
do notAll rightsor
accept reserved.
assumeNot
consequences refers
you to
or the network
context requires,
on it.
network
exercise of member
member of

A7. Angola has not been the subject of a FATF Mutual Evaluation. However, in February 2012 and in June 2012, FATF published a Global
AML/ CFT Compliance publication where Angolas AML regime is briefly analysed. The links to these publications are http://www.fatf-
gafi.org/countries/s-t/turkmenistan/documents/improvingglobalamlcftcomplianceon-goingprocess-16february2012.html (February 2012)
http://www.fatf-gafi.org/countries/a-c/angola/documents/improvingglobalamlcftcomplianceon-goingprocess-22june2012.html (June 2012).

The last IMF Country Report was published in May 2012. The report is the sixth country review under the stand-by agreement. The reports
link is http://www.imf.org/external/pubs/cat/longres.aspx?sk=25888.0
The country page (Angola and IMF) is http://www.imf.org/external/country/ago/index.htm.

.
Q8.
This publicationArehasthere minimum
been prepared transaction
for general guidancethresholds, underforwhich
on matters of interest customer
the personal use of due diligence
the reader, is not
and does notconstitute
required?professional advice. You should not act upon the information
A8. Yes - occasional transactions under USD15,000 (or equivalent in local currency).
A9. Individuals - should provide a valid document with: full name, signature, address, profession and work place (when applicable), birth date,
nationality, funds provenience and tax identification number (optional).
Corporates - should provide a valid document with their deeds of incorporation or valid licence (certification should be made through the
card Carto de Identificao de Pessoa Colectiva or Certido do Registo Comercial), the headquarters address, tax identification number,
shareholder identification if more than 20% of the voting rights, and board of directors identification.
A10. The copies of documentation must be certified.
A11. Management Board and shareholder identification must occur if more than 20% of the voting rights are held. Identification and verification
requirements for beneficial owners are the same as those for individuals or companies listed above.
A12. a) where the customer is a State or a Public Sector Entity (at country, regional or local level);
b) where the customer is a Governmental Authority or Public Institute subject to transparent accounting practices and supervision.
A13. Entities shall apply enhanced due diligence measures in respect of customers and transactions which by their nature or characteristics can
present a higher risk of money laundering or terrorist financing. Those measures are always required when operations are carried out with
non face-to-face customers; with Politically Exposed Persons (PEPs), a resident outside the national territory; in the case of correspondent
banking transactions with credit institutions established in third countries; those designated by the competent supervisory authorities and
Private Banking.
A14. A PEP relationship requires additional due diligence. When establishing a relationship with a non resident PEP, the entities should have
appropriate risk based procedures to determine whether the customer is a PEP; have approval from senior management before establishing
business relationships with such customers; take adequate measures to establish the source of wealth and funds involved in the business
relationship or occasional transactions; and conduct enhanced ongoing monitoring of the business relationship.
A15. When establishing a relationship through correspondence with third country banks, this relationship must take into consideration the banks
country and its AML risk, the analysis of the banks internal procedures regarding the international laws of anti-money laundering, the
guarantee of the information accuracy and the banks reputation. In addition, the financial institution should guarantee that the diligence duty
was observed.
A16. Yes.
.
Q17. In what
or implied) is given as to circumstances is additional
the accuracy or completeness of the due diligence
information required
contained for non face-to-face
in this publication, and, to the extenttransactions and/or
permitted by law, relationships? LLP, its members, employees and
A17. Non face-to-face relationships (especially those that can favour anonymity) require additional due diligence. In such relationships, the
institution should either ask for the legal documentation as for additional documentation
to verify/ certify the documentation provided by the
customer. This may be provided by another financial institution or it can be requested that the first payment is made through an account
A16. by
Country Yes.
A17. Non face-to-face relationships (especially those that can favour anonymity) require additional due diligence. In such relationships, the
institution should either ask for the legal documentation as for additional documentation to verify/ certify the documentation provided by the
customer. This may be provided by another financial institution or it can be requested that the first payment is made through an account
opened in the name of the customer with another financial institution.
Reporting
A18. The Suspicious Activity Reports ( SARs) are made to Banco Nacional de Angola - www.bna.ao and Direco Nacional de Investigao e
Inspeco das Actividades Econmicas do Comando Geral da Policia Nacional - http://www.policiaeconomica.gv.ao/ .
A20. No.
A21. No.
A22. No.
A23. No.
A24. No.
A25. No.
.
agents do not accept or assume any liability, responsibility
PwC helps or duty of careand
organisations for any consequences
individuals of you
create the or theyre
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else acting, or refraining
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with more in this
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publication or for any decision based on it. people who are committed to delivering quality in assurance, tax and advisory services. Tell us what matters to you and find out more by visiting us at
www.pwc.com.
PricewaterhouseCoopers International Limited, This
PricewaterhouseCoopers refers to the network of member firms of
eachpublication
of which is has been prepared
a separate for general
and independent guidance
legal
entity. on matters of interest only, and does not constitute professional advice. You should not act upon
United States of America

Key contact: Jeff Lavine Postal address: 1800 Tysons Boulevard Last updated:
Email: jeff.lavine@us.pwc.com McLean, VA 22102-4261, USA January 2013
Tel: +1 (703) 918-1379
General
A1. In 1970 the United States Congress passed the Currency and Foreign Transactions Reporting Act, commonly known as the Bank Secrecy
Act (BSA). The BSA established specific requirements for record keeping and reporting by private individuals, banks and other financial
institutions. Since the passing of the BSA, several other laws have enhanced and amended the BSA to provide additional tools to combat
money laundering. The key laws are:
a) Money Laundering Control Act (1986)

b) Anti-Drug Abuse Act of 1988
c) Annunzio-Wylie Anti-Money Laundering Act (1992)
d) Money Laundering Suppression Act (1994)
e) Money Laundering and Financial Crimes Strategy Act (1998)
f) Uniting and Strengthening America by Providing Appropriate Tools to Restrict, Intercept and Obstruct Terrorism Act of 2001 (USA
PATRIOT Act)
g) Intelligence Reform & Terrorism Prevention Act of 2004
h) Comprehensive Iran Sanctions, Accountability, and Divestment Act of 2010
The USA PATRIOT Act of 2001 is the most significant of the enhancements and amendments to the BSA.
A2. N/A
etc.)? Please include link to the regulator(s) website
A3. The Financial Crimes Enforcement Network (FinCEN) of the U.S. Treasury Department is the US regulator for AML regulations
http://www.fincen.gov/. FinCEN relies on other US regulators to apply and examine for compliance with FinCENs regulations. These other
regulators are as follows:
a) Banking: Depending upon the type of banking charter an institution has, and its membership in the Federal Reserve System, a
banks federal regulator will be one of the following:
a. Board of Governors of the Federal Reserve System (Fed) http://www.federalreserve.gov/
b. Office of the Comptroller of the Currency of the U.S. Treasury Department (OCC) http://www.occ.treas.gov/
c. Federal Deposit Insurance Corporation (FDIC) http://www.fdic.gov/
b) Other Financial Services:
a. Credit Unions: National Credit Union Administration (NCUA) http://www.ncua.gov/Pages/default.aspx
b. Broker Dealers: U.S. Securities and Exchange Commission (SEC) http://www.sec.gov/ and the Financial Industry
Regulatory Authority (FINRA) http://www.finra.org/index.htm
c. Registered Mutual Funds: U.S. Securities and Exchange Commission http://www.sec.gov/
d. Commodity and Futures Firms: U.S. Commodities Futures Trading Commission (CFTC) http://www.cftc.gov/index.htm
and the National Futures Association (NFA) http://www.nfa.futures.org/
e. Money Services Businesses (MSB): The Financial Crimes Enforcement Network (FinCEN) of the U.S. Treasury
Department http://www.fincen.gov/
f. Insurance Companies: The Internal Revenue Service (IRS) of the U.S. Treasury Department http://www.irs.gov/
g. Non-bank residential mortgage lenders and originators as loan or finance companies: The Internal Revenue Service
(IRS) of the U.S. Treasury Department http://www.irs.gov/
c) Non-Financial sector: The Internal Revenue Service (IRS) of the U.S. Treasury Department http://www.irs.gov/
.
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Regulatory Authority (FINRA) http://www.finra.org/index.htm
c.Registered Mutual Funds: U.S. Securities and Exchange Commission http://www.sec.gov/
d.Commodity and Futures Firms: U.S. Commodities Futures Trading Commission (CFTC) http://www.cftc.gov/index.htm
and the National Futures Association (NFA) http://www.nfa.futures.org/
e. Money Services Businesses (MSB): The Financial Crimes Enforcement Network (FinCEN) of the U.S. Treasury
Questions and Answers: f.
Department http://www.fincen.gov/
Insurance Companies: The Internal Revenue Service (IRS) of the U.S. Treasury Department http://www.irs.gov/

c)
g. Non-bank residential mortgage lenders and originators as loan or finance companies: The Internal Revenue Service
(IRS) of the U.S. Treasury Department http://www.irs.gov/
Non-Financial sector: The Internal Revenue Service (IRS) of the U.S. Treasury Department http://www.irs.gov/
A4. Banking: Federal Financial Institutions Examination Council (FFIEC): http://www.ffiec.gov/bsa_aml_infobase/default.htm

Broker Dealers: http://www.sec.gov/spotlight/moneylaundering.htm and http://www.finra.org/Industry/Issues/AML/
Registered Mutual Funds: http://www.sec.gov/spotlight/moneylaundering.htm
. Commodity and Futures Firms: http://www.cftc.gov/IndustryOversight/AntiMoneyLaundering/index.htm and http://www.nfa.futures.org/NFA-
compliance/NFA-futures-commission-merchants/anti-money-laundering.HTML

A5. No.
A6. Yes - a risk based approach to AML is expected by US regulators. BSA/AML US regulatory guidance is provided in the Federal Financial
Institutions Examination Council (FFIEC) BSA/AML Examination Manual (April 2010).
A7. No.
A8. No - basic due diligence is required for all accounts/customers regardless of transaction amounts.
A9. At a minimum, a financial institution must obtain the following identifying information from each customer before opening an account:
a) name
b) address
c) date of birth (for individuals)
d) identification number (e.g. Taxpayer Identification Number (TIN) or passport number)
The identity of the customer must be verified within a reasonable amount of time after the account is opened; however, generally the identity
is verified before an account is opened. The identity is verified by either the use of document verification (see examples below), or through
the use of non-documentary methods (such as by comparing information provided by the customer to public databases/credit bureaus, and
using third party vendors which do comparisons) or a combination of both.
A10. The requirements for document verification and authentication should be commensurate with the level of AML risk, and as such
requirements can differ based upon the account/customer type and assigned risk rating. US regulations do not specify independent
verification or authentication of identification. However, many financial institutions will use a combination of documentary and non-
documentary methods to verify the identity. The non-documentary methods would provide independent validation of identity information
provided by the customer. For individuals, the original government issued photo identification should be seen and when not possible, the
identification should be certified by a notary public.
.
A10. The
Questions requirements for document verification and authentication should be commensurate with the level of AML risk, and as such
andcanAnswers:
requirements differ based upon the account/customer type and assigned risk rating. US regulations do not specify independent

verification or authentication of identification. However, many financial institutions will use a combination of documentary and non-
documentary methods to verify the identity. The non-documentary methods would provide independent validation of identity information
provided by the customer. For individuals, the original government issued photo identification should be seen and when not possible, the
identification
Country by countryshould be certified
comparison of by a notary
high levelpublic.
Know Your Customer and Anti-Money Laundering information
A11. Financial institutions are required to take reasonable steps to obtain and retain information on the beneficial owners of a customer entity and
are required to perform an appropriate level of due diligence on the beneficial owners for any account opened or maintained in the US. The
level of ownership in a customer entity that triggers beneficial owner identification and due diligence should be determined by the AML risk
. profile of the customer. It is generally considered that at a minimum any beneficial owner holding >25% interest in the customer entity
This publication has been
should beprepared
subject for to
general
due guidance
diligence.on matters of interest for the
The percentage of personal use ofthat
ownership the reader, and due
triggers does not constituteshould
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lower You should
as the AMLnot act upon
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theinformation
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completeness of the information contained in this publication, and, to the extent permitted by law, PricewaterhouseCoopers LLP, its members, employees and
publication or for
Foranyidentified
decision based on it.
beneficial owners, the KYC and identification requirements must be followed.
A12. The basic due diligence noted in A9 is required for all accounts/customers opened or maintained in the US that meet the definition of a
customer.
A13. The USA PATRIOT Act requires financial institutions to increase their due diligence standards when dealing with foreign private banking
and correspondent accounts. In addition, customers classified as high risk according to the institution's customer risk rating methodology
would be subject to enhanced due diligence. Factors that would be considered in determining a customer's risk rating would include at a
minimum: geography, nature of business/employment, products and services used. Local guidance also has information on products,
services, customers and entities that pose higher risks and enhanced due diligence for high risk customers, such as:
a) account activity that is substantially cash-intensive;
b) an entity whose account activity consists primarily of questionable funds transfers, especially to/from high-risk jurisdictions;
c) a business entity whose bearer shares are not under bank or trusted third party control;
d) an entity that uses a wide range of bank services, particularly foreign private banking and correspondent services;
e) an entity owned or controlled by off-shore, non-public business entities; or
f) private investment companies or trust accounts;
The KYC program should also include periodic risk based monitoring of the customer information to determine if there are any substantive
changes to the original customer information. High risk customer relationships are generally reviewed annually.
A14. The USA PATRIOT Act requires financial institutions to conduct enhanced scrutiny of private banking accounts requested or maintained by
or on behalf of senior foreign political figures. Risk factors that may require additional due diligence for PEPs include geographic location,
individuals position or authority, products and services used, and complexity of the account relationships.
A15. Enhanced due diligence should be performed for the owners of any foreign bank whose shares are not publically traded. The identity of
each of the owners of the foreign bank, and the nature and extent of the ownership interest of each owner should be determined. Enhanced
scrutiny of the transactions associated with any correspondent accounts should be performed to guard against the increased risk of money
laundering, in order to identify and report any suspicious transactions as required by US regulations and law. The level of enhanced scrutiny
of any account should be supported by the institutions annual AML risk assessment and the customer's risk rating.
In addition to the normal due diligence requirements, enhanced due diligence should include:
a) obtaining information relating to the foreign bank's AML program to assess the risk of money laundering presented by the
correspondent account;
b) monitoring transactions to, from, or through the correspondent account in a manner reasonably designed to detect money
laundering and suspicious activity;
c) obtaining information from the foreign bank about the identity of any person with authority to direct transactions through any
correspondent account that is a payable through account and about the sources and the beneficial owner of funds or other assets
in the payable through accounts; and
d) determining whether the foreign bank for which the correspondent account is maintained in turn maintains correspondent
accounts for other foreign banks that use the foreign bank's correspondent account and if so, take reasonable steps to obtain
information relevant to assess and mitigate any money laundering risks associated with the foreign bank's correspondent
accounts for other foreign banks.
A16. Yes.
.
A17. Financial institutions should take account of money laundering risks inherent to non face-to-face customer relationships. Where a customer
approaches an institution remotely, the institution should deploy additional monitoring controls against transactions originating in these
higher risk accounts. Local guidance includes examples of non-documentary verification methods that a financial institution may use,
including:
a) contacting a customer after the account is opened;
b) requiring identification documentation to be notarised; and
c) comparing the identifying information against fraud and negative check databases, etc.
Reporting
A18. The Financial Crimes Enforcement Network (FinCEN) of the U.S. Treasury Department:
http://www.fincen.gov/forms/bsa_forms/index.html#SAR

2011 1.5 million SARs http://www.fincen.gov/news_room/rp/files/btn17/sar_by_numb_17.pdf

2011 USD15.0 trillion (Source: data.worldbank.org*)
A20. Yes. Additional reporting includes:

a) Currency Transactions Reports (CTR)
b) Report of International Transportation of Currency or Monetary Instruments (CMIR)
c) Foreign Bank Account Report (FBAR); and
d) Transmittal orders for funds transfers (the Travel Rule)
A21. Yes, depending upon the type of transaction for various reporting:
a) SARs transactions aggregating below USD5,000
b) CTRs transactions aggregating USD10,000 or less
c) CMIRs transactions aggregating USD10,000 or less
d) FBARs when the aggregate value of the foreign financial accounts are USD10,000 or less during the calendar year
e) Transmittal orders for funds transfers (the Travel Rule) below USD3,000.
A22. Yes. Penalties for non-compliance are noted in the Bank Secrecy Act, as amended, at http://www.fincen.gov/statutes_regs/bsa/, as well as
in the regulations of Financial Crimes Enforcement Network (FinCEN) at http://www.fincen.gov/.
*
GDP at purchaser's prices is the sum of gross value added by all resident producers in the economy plus any product taxes and minus any subsidies not included in the value of the products. It is
.
Know
A20.
Yes. Additional reporting includes:
a) Currency Transactions Reports (CTR)
b) Report of International Transportation of Currency or Monetary Instruments (CMIR)
c) Foreign
Country by country Bank Account
comparison of Report (FBAR);
high level Knowand Your Customer and Anti-Money Laundering information
d) Transmittal orders for funds transfers (the Travel Rule)
A23. No. While there are no legal or regulatory requirements to use an automated system, the sophistication of monitoring systems should be
dictated by the institutions riskofprofile, with particular emphasis on the composition of higher-risk products, services, customers, entities,
A21. Yes, depending
and geographies.
upon the type transaction for various
a) SARs transactions aggregating below USD5,000
reporting:
b) CTRs transactions aggregating USD10,000 or less

c) CMIRs transactions aggregating USD10,000 or less
d) a FBARs whento the aggregate value of the foreign
with afinancial accountstransaction
are USD10,000
that isoridentified
less during the calendar year
Q24. Is there requirement obtain authority to proceed current/ongoing
e) Transmittal orders for funds transfers (the Travel Rule) below USD3,000.
as suspicious?
A24. No.
Q25.
A22.
Does the local legislation allow transactions to be monitored outside the jurisdiction?
Yes. Penalties for non-compliance are noted in the Bank Secrecy Act, as amended, at http://www.fincen.gov/statutes_regs/bsa/, as well as
in the regulations of Financial Crimes Enforcement Network (FinCEN) at http://www.fincen.gov/.
A25. Yes, but the financial institution should determine which transactions can be monitored outside its jurisdiction on a risk adjusted basis.
*
.
.
www.pwc.com.
This publication
in this guidance
publication, on to
LLP, its You should
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Uruguay
Key contact: Dannys Correa / Gabriel Rodrguez Postal address: 11000 Last updated:
Email: dannys.correa@uy.pwc.com / Address: Cerrito 461, 2nd Floor, January 2013
gabriel.a.rodriguez@uy.pwc.com Montevideo, Uruguay
Tel: +598 29160463 ext. 1377 / 1373
General
A1. 2009 - Law No. 18.494 introduced several modifications to Law 17.835.
2004 - Law No. 17.835 system controls and prevention of money laundering and financing of terrorism
1998 - Law No. 17.016 standards with regard to the misuse of public power (corruption)
Previously, Uruguayan AML Laws focused on the illicit traffic of narcotic drugs but have been gradually extended to other crimes
A2. N/A.
A3. Uruguayan Central Bank (UCB) - http://www.bcu.gub.uy/

Internal Audit of the Nation - http://www.ain.gub.uy/
A4. Yes - the Unit of Financial Information and Analysis (U.I.A.F.) of the UCB has issued guidance with regard to suspicious or unusual
transactions in order to assist the parties required to report these transactions in the detection of unusual or suspicious patterns in customer
behaviour.
Although the published guidelines are not exhaustive, they constitute a collection of types or patterns of transactions that could be linked to
money laundering operations from criminal activities or terrorist financing.
Uruguayan Central Bank - http://www.bcu.gub.uy/
A5. Yes - the Uruguayan Central Bank (UCB), supervisor of the financial system, established the requirement to periodically update information
on existing clients, especially in the case of high risk customers.
A6. Yes - the UCB has established that the supervision process must be proactive and integrity orientated, focused on risks and performed on a
consolidated basis. The Corporate Governance and Internal Control System Regulations which are in force (UCB Circular 1987) establish
that institutions must have a risk framework according to the nature, size and complexity of their transactions. An AML framework is
specifically required.
.
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A5. on existing clients, especially in the case of high risk customers.

Know
Yes - the UCB has established that the supervision process must be proactive and integrity orientated, focused on risks and performed on a
consolidated basis. The Corporate Governance and Internal Control System Regulations which are in force (UCB Circular 1987) establish
that institutions must have a risk framework according to the nature, size and complexity of their transactions. An AML framework is
Country by countryrequired.
specifically comparison of high level Know Your Customer and Anti-Money Laundering information
A7. Participation in GAFISUD (Grupo de Accin Financiera de Sudamrica), according to the Uruguayan Central Bank Report 2010.
.
Q8. Are thereInternational
PricewaterhouseCoopers minimumLimited,
transaction thresholds,
each of which under
is a separate which customer
and independent due diligence is
legal entity. not required?
A8. Yes - customer due diligence is not required on transactions below USD3,000 with occasional customers.
A9. The institutions must identify their customers in compliance with the UCB requirements when they open accounts or when they process
transactions, with the exception of transactions with occasional customers below USD3,000. The UCB regulations establish the minimum
identification requirements for individuals and legal entities.
For individuals these requirements are:

a) name and surname;
b) date and place of birth;
c) identification document;
d) marital status;
e) address and telephone number;
f) main activity or occupation; and
g) volume of income (salary and other earnings).
It should be ascertained whether the customer is acting on their own or on behalf of a third party. In the latter case, the ultimate beneficiary
should be identified. The same information should be obtained on all owners, agents, representatives and those authorised to operate on
behalf of individual clients. It should be ascertained whether the information on level of incomes of these customers constitutes the source of
income of the account.
For legal entities these requirements are:

a) company name;
b) established date;
c) address and telephone number
d) tax identification number;
e) bylaws and other information on the entity as registry number, etc.;
f) main activity;
g) volume of income (on financial statements); and
h) shareholders and ultimate beneficial owners.
The above mentioned data required for individuals must be obtained for those listed as corporate managers and representatives, agents
and those authorised to act on the companys behalf. It should be ascertained whether the information on level of incomes of these
customers constitutes the source of income of the account.
A10. Notary certification and signature verification are required to certify the validity of the documents provided. Each institution also has its own
policies and procedures to verify the documents and its copies.
A11. Financial institutions must implement procedures in order to identify the ultimate beneficial owner of each transaction, verify their identity
and register their names as well.
.
A10. Notary certification and signature verification are required to certify the validity of the documents provided. Each institution also has its own
policies and procedures to verify the documents and its copies.

What are the high level requirements around beneficial ownership (identification and verification)?
Q11.
Know
A11.
Financial institutions must implement procedures in order to identify the ultimate beneficial owner of each transaction, verify their identity
and register their names as well.
A12. Reduced/simplified due diligence arrangements are available to 'occasional customers'. The UCB regulation defines occasional customers
as those who do not demand transactions on a permanent basis and whose total amount of transactions with the institution is less than
USD30,000 on an annual basis.
.
Q13. In what
or implied) is given as to circumstances are enhanced
the accuracy or completeness customer
of the information due diligence
contained measures
in this publication, required?
and, to the extent permitted by law, PricewaterhouseCoopers LLP, its members, employees and
A13. Enhanced customer due diligence measures are required fornetwork

permanent customers. Institutions must analyse each customer and classify
them according
All rights
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to Limited,
their activity,
residence
each of which andand
is a separate
refers to the
riskindependent
profile. Institutions
of member firms of

legal entity. must obtain, evaluate and register additional information about the
financial situation, in order to justify the customers transactions and the origin of funds for those customers classified as high risk and
those with transactions over a certain limit.
A14. Financial institutions should apply additional due diligence procedures in the case of PEPs, their relatives and their associates. Financial
institutions should:
a) rely on procedures that allow them to determine whether a client is a PEP;
b) get senior management approval upon establishing a new relationship with this type of client;
c) take reasonable measures in order to determine the origin of the funds; and
d) carry out a special and permanent assessment of the customers transactions.
A15. For correspondent banking relationships, local institutions must obtain the following information in relation to foreign institutions:
a) the nature of their business;
b) management details;
c) reputation;
d) principal activities and location of the premises;
e) account purpose;
f) regulation and supervision in their country;
g) political context; and
h) procedures applied in order to prevent being used for laundering of assets or financing of terrorism.
A16. Yes - it is not permitted to perform any type of business with financial institutions established in jurisdictions that do not require physical
presence. It is also not permitted to establish a relationship with foreign institutions which allow shell banks to open accounts.
A17. Financial institutions must implement special procedures to verify the relevant identity and to control non face-to-face transactions such as
non-resident or e-banking transactions.
Reporting
A18. Reports are made to the U.I.A.F., which was established by Resolution of the Board of Uruguayan Central Bank
Uruguayan Central Bank - http://www.bcu.gub.uy/

2011 201 SARs (Uruguayan Central Bank)
. GDP (in current prices):
2011
contained in this USD46,710
publication million
without obtaining (Source:
specific data.worldbank.org*
professional advice. The application )and impact of laws can vary widely based on the specific facts involved. No representation or warranty (express
agents do not accept or assume
This results inany liability,
a ratio ofresponsibility
1 SAR fororeveryduty of USD232,4
care for any consequences of you or anyone else acting, or refraining to act, in reliance on the information contained in this
million of GDP.
2011 201 SARs (Uruguayan Central Bank)
2011 USD46,710 million (Source: data.worldbank.org* )
This results in a ratio of 1 SAR for every USD232,4 million of GDP.

A20. By the above mentioned Circular No. 1722 of UCB dated 12/21/2000, transactions considered suspicious can be conducted on a periodic
basis or isolated and that according to the customs of the activity concerned, are unusual, with no apparent economic or legal justification,
or of unusual or unjustified complexity.
Subjects required to report must immediately inform the U.I.A.F regarding transactions covered by this where there is evidence or suspicion
of involvement in the legitimisation of assets derived from criminal activities.
In addition, financial intermediation institutions must notify the Uruguayan Central Bank and provide information regarding physical or legal
persons carrying out the following transactions:
a) operations consisting of coins, currency conversion, foreign cheques, precious metals, bank deposits, shares or other securities
which are easy to redeem, for amounts in excess of USD10,000 or its equivalent in other currencies;
b) receiving and sending of money orders and transfers (including international transfers) for amounts in excess of USD1,000 or its
equivalent in other currencies, regardless of the mode of operation used for execution. Transfers and money orders are exempted
from the obligation to be reported if they are made between bank accounts in cases where both the account of origin and
destination are based in local financial intermediaries;
c) purchase or sale, exchange or arbitration of foreign currency or precious metals for an amount over USD10,000 or its equivalent
in other currencies, where the counterpart is made in cash.
A21. See Q20 above.
A22. Yes - Fines and penalties from Uruguayan Central Bank and National Internal Audit Office.
A23. Yes.
A24. After a present time, if there is no a response from Uruguayan Central Bank regarding the reported transaction, the institution should
consider if it is appropriate to proceed with the transaction with the customer.
A25. No.
.
www.pwc.com.
Peru
Key contact: Nancy Yong / Guillermo Zapata Postal address: Last updated:
Email: nancy.yong@pe.pwc.com / Av. Santo Toribio 143, Piso 8 - January 2013
guillermo.zapata@pe.pwc.com Lima 27, Per
Tel: +(511) 211 6500 Ext. 2029 /
+(511) 211 6500 Ext. 8051
General
A1. The AML was included in the Peruvian Criminal Code, article 293 B, by Legislative Decree 736 on 1991.
However, in 2002, the following regulations became effective:

a) The Law 27765, Anti Money Laundering Criminal Law, which replaced the AML regulation on Peruvian Criminal Law. This law is
not in force since April 2012.
b) The Law 27693, Law that creates the Peruvian Financial Intelligence Unit (AML supervisor, its acronym in Spanish is UIF-Peru).
Then, this law was modified by Law 28009 and 28306.
c) The Supreme Decree 163-2002-EF, Rules of the UIF-Peru, which was modified by Supreme Decree 018-2006-JUS in 2006.
Note that on April 2012, has entered in force the Legislative Decree 1106, Law against Money Laundering, Illegal Mining and Organized
Crime, which has replaced the Law 27765 and its modifications.
A2. The previous AML regime only considered a Money Laundering Crime where the money is obtained by drug trafficking, terrorism, abduction
or human trafficking.
In the current AML regime, illegal mining is also considered as an aggravation.
etc.). Please include link to the regulator(s) website.
A3. Banking, Insurance and Private Pension Fund Manager Superintendence (its acronym in Spanish is SBS) through UIF-Peru is in the
Peruvian regulator for all AML controls and is the AML / CFT National Coordinator at GAFISUD.
A4. SBS Training: http://www.sbs.gob.pe/0/modulos/JER/JER_Interna.aspx?ARE=0&PFL=2&JER=464
A5. The Legislative Decree 1106 includes additional control mechanisms related to criminal law. The requirement is to verify the identity of
customers who are regulated on Supreme Decree 018-2006-JUS, which was not modified.
A6. Under the legal framework mentioned in A.1., the local regulator may issue additional regulations in order to control AML/CFT practices,
such as SBS Resolution 5709-2012, in which the Notary Public must report any suspicious or unusual operation to the UIF-Peru.
.
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A5. The Legislative Decree 1106 includes additional control mechanisms related to criminal law. The requirement is to verify the identity of
customers who are regulated on Supreme Decree 018-2006-JUS, which was not modified.

A6. Under the legal framework mentioned in A.1., the local regulator may issue additional regulations in order to control AML/CFT practices,
such
Country by as SBS Resolution
country comparison 5709-2012,
of highin level
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Laundering to the UIF-Peru.
information
A7. Last Mutual Report FATF/GAFI was executed on July 2005): http://www.fatf-gafi.org/countries/n-r/peru/
.
A8. According to Supreme Decree 018-2006-JUS, the supervised entities must report to UIF-Peru the following situations:
a) Clients operations which amounts to USD10,000 (or its equivalent in PEN) or any other higher amount. In case of fund transfer
companies, casinos, lottery companies, bingos, among others, the supervised entity must report any transaction which amounts
to USD2,500 (or its equivalent in PEN) or any other higher amount.
b) Operations executed in one or more offices of the supervised entity in favour of the same person, which amounts to USD50,000
(or its equivalent in PEN) or any other higher amount. In case of fund transfer companies, casinos, lottery companies, bingos,
among others, the supervised entity must report any transaction which amounts to USD10,000 (or its equivalent in PEN) or any
other higher amount.
A9. Individuals: Complete surname and name, birth date, identification document, profession or occupation and domicile.
Legal entities: name, taxpayer registration number, purpose, and legal representative information (complete surname and name, birth date,
identification document, profession or occupation and domicile).
A10. The supervised entity must report to the UIF-Peru the following:
a) Description of the operations executed, including dates, amounts, currency, place of the operation and other supporting
documentation (bank statements, credit/debit notes, deposit or withdraw certificates, documents used in funds transfer, copy of
checks, cashiers check among others).
b) Aspects in order to consider the operation as suspicious.
c) Other relevant information or documentation.
A11. There are the same high level requirements mentioned in A10.
A12. In accordance to SBS Resolution 838-2008, article 9.1, reduced/simplified due diligence measures are applicable in cases where the
products, services and distribution channels mitigate the risks by limiting the amounts transacted and the type of available transactions,
among other special mechanisms.
In order to apply for the reduced/simplified due diligence arrangements, the supervised entity must apply for an authorization from the SBS,
including the following documentation:
a) information relating to the product characteristics.
b) report in which is defined the commercial and operative design of the product, including distribution channels.
c) risk Management Program applicable to the product.
.
A12. In accordance to SBS Resolution 838-2008, article 9.1, reduced/simplified due diligence measures are applicable in cases where the
products, services and distribution channels mitigate the risks by limiting the amounts transacted and the type of available transactions,
among other special mechanisms.
Questions
In order and
to applyAnswers:
for the reduced/simplified due diligence arrangements, the supervised entity must apply for an authorization from the SBS,

including the following documentation:
a) information relating to the product characteristics.
b) report in which is defined the commercial and operative design of the product, including distribution channels.
c) risk Management Program applicable to the product.
A13. In accordance to SBS Resolution 838-2008, article 9.2, enhanced due diligence measures are applicable to the following customers:
a) National and foreign clients, non domiciled.
b) Trusts.
c) Non domiciled companies.
d) PEPs.
e) Correspondent banking operations with foreign legal entities, especially the ones incorporated in tax havens or in countries
. without banking supervision.
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i) Clients under investigation of money laundering, precedent crimes and/or financing terrorism.
j) Clients related to individuals or legal entities under investigation or judicial procedures related to money laundering, precedent
crimes and/or financing terrorism.
k) Clients with bank accounts in Foreign Currency according to the amounts mentioned in A8.
l) Legal entities in which their shareholders, partner or associates that have directly or indirectly, more than the 5% of its capital
stock, contribution or participation, are individuals or legal entities.
m) Other customers with unusual or suspicious operations.
A14. According to SBS Resolution 838-2008, article 9.2., the supervised entities are entitled to carry out an enhanced regime procedure for
PEPs. They must identify and register the PEPs in case they execute transactional patterns that do not belong to their profile. PEPs are also
supervised by the Contraloria General de la Repblica, which is the Peruvian agency in charge of the supervision of Public Official
functions.
Note that the partners, shareholders or associates and administrators of legal entities in which a PEP is the owner of a percentage equal to
or more than 5% of the capital stock of the referred legal entity, are also supervised under the enhanced regime procedure.
A15. According to SBS Resolution 838-2008, article 11, corporations under Financial System Regulations, as well as Credit Unions, must
execute policies and procedures related to the prevention or detection of unusual and suspicious operations carried out between national or
foreign legal entities. In this case, the supervised entities under the Peruvian AML Legal Framework must identify the risk exposure for
correspondent banking relationships and must know the nature and the scope of the correspondent banks operations, and must evaluate
the quality of the AML / CFT System in the correspondent bank and the compliance of UIF-Peru regulations, especially in correspondent
banks domiciled in countries with strict regulations or tax havens.
A16. According to SBS Resolution 838-2008, article 11, the local legal entities must have policies and procedures related to operations with
correspondent banking relationships with shell banks and must obtain a certificate in which is stipulated that the foreign correspondent bank
(to which the local entity maintain correspondent banking relationships) does not allow shell banks to use its accounts.
A17. There are no additional due diligence required for non face-to-face transactions and/or relationships.
Reporting
A18. UIF-Peru of the SBS: http://www.sbs.gob.pe
.

January to October 2012 2,543 SARs (http://www.sbs.gob.pe/repositorioaps/0/2/jer/esta_transparenciaoperativa/2012/octubre_2012.pdf)
GDP data is not available for this specific period.
A20. Law 27693, article 9 stipulates the operations to be reported according to the amounts mentioned in A8. Moreover, Law 27693, article 11
stipulates the definition of suspicious and unusual transactions.
A21. Yes. Please see A8. However, in case the transaction is suspicious or unusual, it must be reported.
A22. Penalties for non compliance with Law 29038 requirements are detailed on SBS Resolution 1782-2007.
A23. Article 1 of SBS Resolution N 9810-2011, stipulates that regulated entities are requested to use automated Suspicious Transaction
Monitoring Technology (its acronym in Spanish is ROSEL) to report suspicious transactions.
A24. There are no limitations related to this aspect. Once the transaction is executed, the supervised entity must report the operation and the
customers information.
A25. There are no local regulations related to this matter.
people who
This publication has been prepared for general guidance on are committed
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Paraguay
Key contact: Rubn Taboada /Justo Bez / Postal address: General Daz Nro. 521 Last updated:
Viviana Gonzlez Edificio Internacional Faro Piso 6, Asuncin January 2013
Email: ruben.taboada@py.pwc.com /
justo.baez@py.pwc.com /
viviana.gonzalez@py.pwc.com
Tel: +595 21 445003
General
A1. 1997.
A2. N/A.
A3. Secretara de Prevencin de Lavado de Dinero (SEPRELAT) www.seprelad.gov.py/
A4. No.
A5. No.
A6. No.
Q7. Has the country been the subject of a FATF (or FATF-style) Mutual Evaluation or IMF assessment exercise in the last 3 years? If yes,
A7. No.
A8. Yes - Due diligence procedures are not required on transactions below USD10,000.
.
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A9. The law and its procedures define minimum requirements to identify customers:
Individuals: birth date; nationality; National Identification number (cdula de identidad) or passport number; Registro Unico de
Contribuyente (RUC) if applicable, which is the Taxpayers Identification Number); marital status and spouses name (if applicable); home
and business address; telephone number; profession; occupation; and commercial references.
Legal entities: Entity name; activity; Regstro Unico de Contribuyente (RUC), which is the Taxpayers Identification Number; business
address; telephone number; shareholders list; executives list; commercial references; and entity constitutive documents.
A10. According to law, financial institutions should always verify original identification documents. However, for legal entities, there are some
documents that can be provided as copies, if those copies are certified by a notary public officer.
A11. The following three situations require financial institutions to collect additional information about beneficial ownership:
a) when the client informs the institutions that the final beneficiary is another person or entity;
b) when the financial institution has doubts about the final beneficiary; or
c) when the customer engages in commercial, financial or industrial transactions in a location where they have no operations.
No requirements are established around verification of this data.
A12. No specific procedures or guidance exist on this situation, only that documents are not required for operations below USD10,000.
A13. Enhanced due diligence arrangements are required for transactions above the USD10,000 threshold.
A14. There are specific requirements to classify the customer as high risk - its operations must be approved by the highest authority of institutions
to establish due diligence procedures to apply, including spouses, relatives and relatives up to fourth degree of consanguinity, second
degree of affinity. Nonprofit organisations are also included.
A15. The correspondent must be approved by the highest authority of the institution; it must know the nature of the activities of the
correspondent, and evaluate the policies and procedures to prevent money laundering and terrorist financing implemented by the
correspondent. On account transfers have correspondent evidence that preventative measures have been implemented and due diligence
procedures performed on transfers.
A16. No.
A17. The entity must develop policies and procedures relating to prevention to avoid the use of technological devices to perform operations
related to ML and TF, as well as keeping up to date computer platforms.
.
Reporting
Q18.
To whomInternational Limited, each
are Suspicious of which
Activity is a separate
Reports (SARs)and independent legal entity.
made? Please include a link to their website.

Know
The entity must develop policies and procedures relating to prevention to avoid the use of technological devices to perform operations
related to ML and TF, as well as keeping up to date computer platforms.
Reporting
A18. The Secretara de Prevencin de Lavado de Dinero (SEPRELAT) www.seprelad.gov.py
A20. Institutions must also report suspicious transactions, fund transfer operations to and from other countries (transfers, exchanges, cash
checks, or any other payment method), as well as physical remittance of money.
A21. Yes. Anything below USD10,000.
A22. Yes.
A23. Yes.
A24. No.
A25. No.
.
2009 PricewaterhouseCoopers. All rights reserved. PricewaterhouseCoopers
PwC helps
PricewaterhouseCoopers International Limited, people
each ofwho
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theyre looking
tax and advisory services. Tell us what matters to you and find out more by visiting us at
www.pwc.com.
Mexico
Key contacts: Martin Montealegre / Sophie Postal address: Last updated:
Demier Mariano Escobedo No. 573 January 2013
Email: martin.montealegre@mx.pwc.com / Col. Rincn del Bosque
sophie.demier@mx.pwc.com CP 11580, Mxico D.F.
Tel: +52 (55) 5263 5775 / +52 (55) 5263 MXICO
5462
General
A1. There are different laws that apply to the financial sector and the issue date of each General Provisions please contact Martin or Sophie
for further details.
A2. There are different standards for each type of financial institution. Some AML regulations became effective in the last two years, mainly to
regulate the activity of the Multiple Purpose Financial Societies (SOFOMs) and Credit Unions. In addition, in October 2012 Mexican
authorities issued the new Federal Law for the Prevention and Identification of Operations with Illegal Resources to regulate Designated
non-Financial Businesses and Professions.
Prior to 2011 SOFOMs were not subject to AML regulations. In the case of the Credit Unions, they previously were subject to the general
provisions of The General Organizations with Auxiliary Credit Activity.
.
agents
2013 PwC.
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A2. There are different standards for each type of financial institution. Some AML regulations became effective in the last two years, mainly to
regulate the activity of the Multiple Purpose Financial Societies (SOFOMs) and Credit Unions. In addition, in October 2012 Mexican
authorities issued the new Federal Law for the Prevention and Identification of Operations with Illegal Resources to regulate Designated

non-Financial Businesses and Professions.
Prior to 2011 SOFOMs were not subject to AML regulations. In the case of the Credit Unions, they previously were subject to the general
provisions of The General Organizations with Auxiliary Credit Activity.
A3. In Mexico, various organisms regulate AML controls, depending on the type of financial institution.
Regulator 1: Comisin Nacional Bancaria y de Valores (CNBV, National Banking and Securities Commission)
Regulated Institutions
Commercial banks
Development Banking Institutions
Limited Purpose Financial Society (SOFOL)
Broker Houses
Societys Managing Mutual Funds (Sociedades Operadoras de Sociedades de Inversin)
Distribution Societys of Mutual Fund Shares
Financial Lessor
Financial Factoring companies
General Deposit Warehouses
Credit Unions
Societys for Saving and Loans
Foreign Exchange Houses
Multiple Purpose Financial Society (SOFOM)
Entity of Saving and Popular Credits
Foreign Exchange Centers
Money transmitters
Regulator 2: Comisin Nacional de Seguros y Fianzas (CNSF, National Insurance and Surety Institution)
Regulated Institutions
Insurance Institutions
Surety Institutions
Regulator 3: Comisin Nacional de Sistemas de Ahorro para el Retiro (CONSAR, National Retirement Savings System
Commission)
Regulated Institution
Retirement Fund Managers
Regulator 4: Secretara de Hacienda y Crdito Pblico (SHCP, Secretary of Finance and Public Credit)
Actividades vulnerable (Designated non-Financial Businesses and Professions)
.
Contests,
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or implied) is given as to theGranting
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completeness of the information contained in this publication, and, to the extent permitted by law, PricewaterhouseCoopers LLP, its members, employees and
Buying
publication or for any decision based onandit. Selling of precious metals and stones, jewelry watches and art
Sale or lease of aircraft, marine or terrestrial vehicles
TransferLimited,
PricewaterhouseCoopers International or custody
each ofof money
which or securities
is a separate and independent legal entity.
Armor-plating services
Professional service, in a independent manner, when preparing and performing on behalf of a third person any of the following
operations:
1. Purchase or sell of real estate
2. Management of securities or assets
3. Management of bank accounts, savings or assets
4. Constitution, de merge, merge, operation and management of corporations
Public Notaries
Forwarding agent
Non Profit Organizations
Leasing of real estate
A4. The Ministry of Finance and Public Credit (Secretaria de Hacienda y Credito Publico, SHPC), via the Official Journal of the Federation
publishes practical guidance to firms regarding AML requirements and best practices for AML prevention.
Ministry of Finance and Public Credit (Secretaria de Hacienda y Credito Publico, SHPC)
The SHCP has a section of FAQs aimed at fomenting a culture of AML prevention in financial institutions as well as non-financial
institutions.
http://www.shcp.gob.mx/INTELIGENCIA_FINANCIERA/Paginas/Preguntas_Frecuentes.aspx
National Banking and Securities Commission (Comisin Nacional Bancaria y de Valores, CNBV)
Taking into account that the prevention of crime starts with educating and diffusing a culture of prevention, the CNBV created the present
section with the purpose of educating the public in a practical way, about different aspects related to AML/CFT.
http://www.cnbv.gob.mx/PrevencionDeLavadoDeDinero/Paginas/Cultura.aspx
.
contained in this
Is publication without obtainingto
there a requirement specific professional advice.
retrospectively verifyThe
theapplication
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of impact of laws before
customers can vary widely based
the date on new
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AMLfacts involved.
regime was Nointroduced?
representation or warranty (express
Q5.
publication or for
Theanyfinancial
decision based on it.has historically applied KYC policies, but under an internal controls approach rather than for the purpose of anti-money
sector
A5.
Ministry of Finance and Public Credit (Secretaria de Hacienda y Credito Publico, SHPC)
The SHCP has a section of FAQs aimed at fomenting a culture of AML prevention in financial institutions as well as non-financial
institutions.
http://www.shcp.gob.mx/INTELIGENCIA_FINANCIERA/Paginas/Preguntas_Frecuentes.aspx
Questions
Nationaland Answers:
Banking and Securities Commission (Comisin Nacional Bancaria y de Valores, CNBV)

Taking into account that the prevention of crime starts with educating and diffusing a culture of prevention, the CNBV created the present
section with the purpose of educating the public in a practical way, about different aspects related to AML/CFT.
http://www.cnbv.gob.mx/PrevencionDeLavadoDeDinero/Paginas/Cultura.aspx
A5. The financial sector has historically applied KYC policies, but under an internal controls approach rather than for the purpose of anti-money
laundering prevention.
A6. There is not an official risk approach model established by the authority, but the general provisions require the entity to integrate a model
based on parameters which classifies their clients depending on the risk they represent, establishing at least two levels of risk: low and high
risk customers.
Q7. Has the country been the subject of a FATF (of FATF-style) Mutual Evaluation or IMF assessment exercise in the last three years? If yes,
A7. Mexico was initially evaluated by the GAFI in 2008, since then GAFI and GAFISUD have issued monitoring reports in 2009, 2010, 2011 and
2012.
a) Mutual Evaluation Report of Mexico by GAFI

a. 2008
b) Monitoring report by GAFI

a. October 2010
b. October 2011
c. October 2012
c) Monitoring report by GAFISUD

June 2009
December 2009
June 2010
December 2010
June 2011
December 2011
June 2012
A8. Each of the different entities that are subject to AML general provisions as mentioned in answer 3 consider different transaction thresholds,
depending on the type of products and services that they each provide.
A9. Requirements for customer identification information may vary according to financial entities, but in general they include:
.
This publicationInhas
thebeen
case of individuals:
prepared for general guidance on matters of interest for the personal use of the reader, and does not constitute professional advice. You should not act upon the information
a) Full name
agents do not accept b) Date
or assume ofliability,
any birth responsibility or duty of care for any consequences of you or anyone else acting, or refraining to act, in reliance on the information contained in this
publication or for any c)
decisionNationality
based on it.
d) Employment
e) International
PricewaterhouseCoopers Code of Limited,
information
All rights reserved.
Taxpayer
each registration (RFC)and independent legal entity.
of which is a separate
f) Serial number of Advanced Electronic Signature
g) Proof of address
h) Telephone number
i) E-mail
In the case of corporations:

a) Corporate name
b) Economic activity or social activity
c) Nationality
d) Code of taxpayer registration (RFC)
e) Serial number of Advanced Electronic Signature
f) Proof of address
g) Telephone number
h) E-mail
i) Date of constitution
In the case of corporations:
a) Corporate name
b) Economic activity or social activity
c) Nationality
d) Code of taxpayer registration (RFC)
e) Serial number of Advanced Electronic Signature
f) Proof of address
g) Telephone number
h) E-mail
i) Date of constitution
A10. Copies of identification documentation are provided at the initial stage of the commercial relationship, at the time the Client File is created.
While there is no legal requirement around independent verification or authentication of identification documentation, some institutions are
implementing authenticity measures, some of which include black lights and special training courses for detecting false Ids.
A11. Requirements for the identification of the beneficiary may vary depending on the type of client and the institution that requires them, but in
general they include:
a) Full name
b) Date of birth
c) Proof of address
d) Same documents required by client
e) If a document presents scraps or has been repaired the entity should ask for this other information: 2 bank references or
commercial references that contain the aforementioned data.
A12. When the client is considered a low risk client.
Q13. In what circumstances is enhanced-customer due diligence measures required?
A13. a) Client personal interview

b) Visits to clients address
c) Criteria to classify the risk a client represents.
d) Transactions made with dollars from the United States of America (Credit Institutes and foreign exchange houses)
e) Currency Operation Reports of transactions made in United States of America Dollars (Credit Institutes and foreign exchange
houses)
f) Reports of international transfers of funds (Credit Institutes and foreign exchange houses)
g) Exchange of information between entities
h) Know Your Customer and/or User Policies
A14. The Ministry of Finance and Public Credit (Secretara de Hacienda y Crdito Pblico, SHPC), provides the public with a list of criteria for
.
This publicationdetermining whether
has been prepared a customer
for general guidance onshould
matters be considered
of interest as politically
for the personal use of theexposed,
reader, and see theconstitute
does not following link: advice. You should not act upon the information
professional
http://www.hacienda.gob.mx/LASHCP/MarcoJuridico/InteligenciaFinanciera/Paginas/ListaPersonasPoliticamenteExpuestas.aspx
Q15. What enhanced
PricewaterhouseCoopers due
International diligence
Limited, each ofmust bea separate
which is performed for correspondent
and independent legal entity. banking relationships
(cross-border banking and similar relationships)?
A15. Mexican regulation does not require that enhanced due diligence be performed for correspondent banking relationships. Each entity
establishes its own criteria and mechanisms of control and prevention. Generally entities that respond to a foreign corporate base have
stricter AML controls.
A16. Yes, according to AML General Provisions.
A17. Depending on the amount of the transaction, some institutions require additional information to support that transaction.
Reporting
A18. Reports are sent to the Secretara de Hacienda y Crdito Pblico (SHCP) via the respective regulatory bodies of each entity (see answer 3).
A16. Yes, according to AML General Provisions.

Know
A17.
Depending on the amount of the transaction, some institutions require additional information to support that transaction.
Reporting
A18. Reports are sent to the Secretara de Hacienda y Crdito Pblico (SHCP) via the respective regulatory bodies of each entity (see answer 3).
A19.
Unusual Transaction Reports Worrisome Internal Operation
Relevant Transaction Reports U.S dollars Cash Transactions Report
.
A20. In most financial entities, there are thresholds for relevant operations, cash transaction, international fund transfers and US dollar
transactions above which a suspicious activity report must be filed. For further details, please contact Martin or Sophie
In addition, a transaction is to be considered suspicious in the follow circumstances:

a) When a manager, officer, employee or agent of the entity, maintains a standard of living well above that would correspond,
according to the earnings of the person in question.
b) When, without reasonable cause a director, officer, employee or agent of the entity has repeatedly participated in operations that
have been reported as unusual transactions.
c) When, without reasonable cause there is a gap between the functions that a manager, officer, employee or agent should do, and
the activity the person in question actually carries out.
transactions above which a suspicious activity report must be filed. For further details, please contact Martin or Sophie
In addition, a transaction is to be considered suspicious in the follow circumstances:

a) When a manager, officer, employee or agent of the entity, maintains a standard of living well above that would correspond,
according to the earnings of the person in question.
b) When, without reasonable cause a director, officer, employee or agent of the entity has repeatedly participated in operations that
have been reported as unusual transactions.
c) When, without reasonable cause there is a gap between the functions that a manager, officer, employee or agent should do, and
the activity the person in question actually carries out.
Q21. Are there any minimum thresholds below which transactions do not need to be reported?
. transactions, below which a suspicious activity report does not need to be filed. For further information, please contact Martin or Sophie.
Q22. Are there
agents do not accept any any
or assume penalties for non compliance
liability, responsibility or duty of carewith reporting
for any requirements
consequences e.g.else
of you or anyone tipping
acting,off?
or refraining to act, in reliance on the information contained in this
A22. Yes, according
PricewaterhouseCoopers to AML
International General
Limited, Provisions.
A23. Entities must have automated systems which must have the following functions:
a) Maintain and update data to allow consultation of the records.
b) Generate, encode, encrypt and securely transmit to the secretary, through the commission, information on significant transactions
reports, unusual operation, and international transfers.
c) Classify types of operations or financial products offered by entities to their customers or users.
d) Detect and monitor the operations performed by a client or by the same user from those indicated.
e) Run warning systems that contribute to the detection and monitoring of suspicious activity analysis.
f) Group on a consolidated basis of the different contracts to the same client.
g) Maintain historical records of possible worrisome internal operations and Unusual Operations.
h) Serve as a means for the agency staff so they can report to internal areas that they determine, in a safe, confidential and
auditable way.
i) Maintain security schemes of information processed.
j) Run an alert system on operations that intend to carry out with people linked to terrorism or its financing, or other illegal activities.
A24. Yes, according to General provisions.
A25. No.
www.pwc.com.
Jamaica
Key contact: Peta-Gaye Bartley Postal address: Last updated:
Email: peta-gaye.s.bartley@jm.pwc.com Scotiabank Centre, Duke Street January 2013
Tel: +1 (0) 876 922 6230 P.O. Box 372,
Kingston, Jamaica
General
A1. 1996 (amended 2007).
A2. N/A.
A3. Financial Services Commission (FSC) www.fscjamaica.org.

Bank of Jamaica www.boj.org.jm
A4. The Financial Services Commission provides guidance on AML (revised March 30 2007) www.natlaw.com .
A5. No.
A6. No - although the regulations do not specifically approve a risk based approach, they generally encourage companies to identify and
monitor key company risks to ensure that anti money laundering detection and reporting guidelines are being followed.
A7. The last Financial System Stability Assessment done by the IMF on Jamaica was in March 2006.
http://www.imf.org/external/pubs/ft/scr/2006/cr06156.pdf.
.
2013 PwC.
accept reserved.
assumeNotanyfor furtherresponsibility
consequences refers
context requires,
on it.
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another firms of
member

monitor key company risks to ensure that anti money laundering detection and reporting guidelines are being followed.
Questions and
please find a linkAnswers:
to a relevant report (if publicly available).
Know
The last Financial System Stability Assessment done by the IMF on Jamaica was in March 2006.
http://www.imf.org/external/pubs/ft/scr/2006/cr06156.pdf.
A8. Yes - all transactions above the thresholds must be reported to the required institutions. There are some institutions that are exempt from
. submitting threshold transactions such as embassies, high commissions, government agencies and statutory bodies.
Under theprepared
Proceedfor general guidance
of Crime (POCA)on matters of interest for2007,
Regulations the personal use of the reader,
the Threshold and does not
Transaction constitutemust
Reports professional advice. You
be prepared forshould not act uponin
transactions thecash
information
equal
to or exceeding threshold of USD15,000. The threshold for remittance companies and cambio transactions are USD5,000 and USD8,000
respectively.
A9. Individuals require a registered name, date and place of birth, nationality, address etc. As part of the verification process, the name and
address of the customer should be verified by an independent source, for example passport, identity card, driving licence, current utility bill,
telephone directory or the voters poll.
For a partnership, an unincorporated business and companies, the partnership agreement, Certificate of Incorporation, Memorandum &
Articles of Association, most recently filed annual return, copies of powers of attorney or other authorities given by directors in relation to the
company are required.
For large corporate accounts, the following amongst other documents may be obtained:
a) Certificate of Incorporation;
b) Memorandum & Articles of Association;
c) the most recent annual return filed with the Registrar;
d) the name(s) and address(es) of the beneficial owner(s) and/or the person(s) on whose instructions the signatories to the account
are empowered to act; and
e) Copies of identification documents should be obtained from at least two directors.
A10. Emphasis is placed on original documentation where available. The regulations do not specifically state what copies of documentation can
be certified by external third parties. They also require, in some instances, independent verification of the documentation presented by the
customer.
A11. There is no specific information in local guidance which deals specifically with beneficial ownership. However, firms should carry out
verification in respect of the parties operating the account. Where there are underlying principals, the true nature of the relationship between
the principals and the account signatories must also be established. Appropriate enquiries should be performed on the principals, especially
if the signatories are accustomed to acting on their instructions. In this context principals should be understood in its widest sense to
include, for example, beneficial owners, settlers, controlling shareholders, directors, major beneficiaries etc.
A12. Verification of the institution is not needed for five types of eligible institutions, including a licensed bank, a financial institution licensed
under the Financial Institutions Act, a building society registered under the Building Societies Act, a society registered under the Co-
operative Societies Act and an insurance company registered under the Insurance Act.
Q13. In what circumstances are enhanced customers due diligence measures required?
A13. Financial institutions are required to implement enhanced due diligence for transactions involving high risk activities, businesses, foreign
countries and linked accounts. This requires stricter KYC procedures, for example more detailed information on the customers background
and reputation as well as management information systems to monitor accounts with greater frequency than low risk accounts and senior
management approval for the establishment of accounts.
.
operative Societies Act and an insurance company registered under the Insurance Act.
Q13. In what circumstances are enhanced customers due diligence measures required?
A13. Financial institutions are required to implement enhanced due diligence for transactions involving high risk activities, businesses, foreign
countries and linked accounts. This requires stricter KYC procedures, for example more detailed information on the customers background
and reputation as well as management information systems to monitor accounts with greater frequency than low risk accounts and senior
management approval for the establishment of accounts.
A14. Financial institutions are required to implement enhanced due diligence for transactions involving Politically Exposed Persons ('PEPs'). All
regulated entities must also:
a) obtain adequate documentation regarding the PEP;
b) understand the PEPs anticipated account activity;
c) determine the PEPs source of wealth; and
d) apply additional oversight to the PEP's account.
.
or implied) is given
What as enhanced
to the accuracy or completeness
due of the information
diligence must contained
be performed forincorrespondent
this publication, and, to the extent
banking permitted by law,
relationships PricewaterhouseCoopers
(cross-border banking LLP,anditssimilar
members, employees and
relationships)?
Q15.
A15. The following enhanced

a) International
PricewaterhouseCoopers Articles of
due diligence
Association,
Limited,
should be obtained
Certificate
each of which ofand
is a separate Incorporation
bynetwork
refers to the
independent legal
corresponding
and
banks:
of member firms
certified copies of
of
the banking licence determining ownership of the
entity.
financial institution, members of the board of directors and management composition.
b) approval must be granted by senior management to open the account.
A16. Yes.
A17. In accepting business from non face-to-face customers, financial institutions should apply equally effective customer identification
procedures as for those customers available for interview and there must be specific and adequate measures to mitigate the higher risk.
Measures to mitigate risk may include requisition of additional documents to complement those which are required for face-to-face
customers.
Reporting
A18. The Financial Investigations Division. In Jamaica, such reports are referred to as the Suspicious Transactions Reports (STRs).
http://www.mof.gov.jm/fid
A19. Information on the volume of SARs not publicly available.
A20. Yes, transactions over a certain threshold should be reported to the Financial Investigations Division. Also refer to A8 above.
A21. No, all suspicious transactions should be reported.
.
A20. Yes, transactions over a certain threshold should be reported to the Financial Investigations Division. Also refer to A8 above.

No, all suspicious transactions should be reported.

A21. by country comparison of high level Know Your Customer and Anti-Money Laundering information
Country
A22. Yes there are penalties. Failure to comply with the provision of the law may result in commercial prosecution, commercial losses, negative
publicity, etc. Failure to file suspicious transaction reports with the designated authority will attract up to 1 year imprisonment jail or JMD1
. million (Resident Magistrate, RM Court). Failure to file a threshold transaction report attracts a fine of up to JMD400,000 (RM Court). In
respect
contained in this to without
publication tippingobtaining
off a company can beadvice.
specific professional fined The
up application
to JMD600,000
and impact(RM Court).
of laws can vary widely based on the specific facts involved. No representation or warranty (express
A23. No.
A24. There is no requirement to obtain authority to proceed.
A25. No.
www.pwc.com.
. This publication has been prepared for general guidance on matters of interest only, and does not constitute professional advice. You should not act upon
the information
This publication has been prepared for general guidance contained
on matters in thisforpublication
of interest the personal without
use ofobtaining specific
the reader, professional
and does advice.
not constitute No representation
professional or warranty
advice. You (express
should not or implied)
act upon is given as
the information
to the accuracy
contained in this publication without obtaining specific or completeness
professional of the information
advice. The application and impactcontained in this
of laws can publication,
vary and,ontothe
widely based thespecific
extent permitted by law,
facts involved. NoPwC does do not
representation or accept
warrantyor(express
assume
any liability,
or implied) is given as to the accuracy or completeness of theresponsibility or duty of in
information contained care
thisfor any consequences
publication, ofextent
and, to the you orpermitted
anyone else acting,
by law, or refraining to act, in reliance
PricewaterhouseCoopers LLP, its on the information
members, employeescontained
and
in this publication
agents do not accept or assume any liability, responsibility or duty or
of for
careany
fordecision based on it.of you or anyone else acting, or refraining to act, in reliance on the information contained in this
any consequences
Colombia
Key contact: Steven Koegler Postal address: Last updated:
Email: steven.koegler@co.pwc.com Calle 100 No 11-A-35; 8th. Floor; January 2013
Tel: +571 6340528 or 6240555 ext 485 Bogot; Cundinamarca; Colombia
General
A1. 1996. Financial institutions had to comply with the SIPLA (Integral System for the Prevention of Assets Laundering) regulation by reporting
financial transactions over defined limits. In 2008, the Superintendent of Finance of Colombia issued External Circular No. 022 2007,
regarding the implementation of the System for Preventing Assets Laundering and Terrorism Financing (SARLAFT) with a risk based
approach. The 2009 regulation incorporates some new reporting standards that must be adhered to when reporting to the Regulator.
A2. The main features of the SIPLA regulation included implementing adequate KYC procedures, monitoring transactions, investigating unusual
transactions and reporting any suspicious transactions to the relevant authorities.
A3. SARLAFT requirements are issued by the regulator, the Superintendence of Finance of Colombia. Entities have to report to the Financial
Information and Analysis Unit (UIAF) of Colombia
A4. The regulation provides specific details of how the SARLAFT should be considered by financial institutions. Although the segmentation
methodologies and activities related to risk management and transactional monitoring should be designed by each individual entity.
http://www.superfinanciera.gov.co/Normativa/NormasyReglamentaciones/cir007/cap11lavadodeactivos.doc
A5. Yes new regulation establishes the parameters for KYC procedures which incorporate the requirement to update a customers information.
A6. Yes new regulation has a risk based approach regarding AML.
A7. No.
.
or2013
implied)
PwC.is All
given as reserved.
rights to the accuracy
Not fororfurther
completeness of the
distribution information
without contained
the permission in thisPwC
of PwC. publication,
refers and,
to thetonetwork
the extent permittedfirms
of member by law, PricewaterhouseCoopersInternational
of PricewaterhouseCoopers LLP, its members,
Limited employees
(PwCIL), or,and
as the
agents requires,
context do not accept or assume
individual memberany liability,
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PwC network. or duty
Eachof care forfirm
member anyisconsequences
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PwCIL does in thisany services
not provide
responsible or liable for the acts or omissions
of any other
All rights reserved. member firm nor can it control
PricewaterhouseCoopers refers the exercise
to the
International Limited, each of which is a separate and independent legal entity.
of another
network of member member
firms firms
of

A6. Yes new regulation has a risk based approach regarding AML.
Q7. please find
Questions anda linkAnswers:
Know
No.
.
A8.
This publicationYes
has -been
there are various
prepared for generalthresholds depending
guidance on matters on for
of interest thethetype of transaction,
personal including
use of the reader, and does no customer
not constitute due diligence
professional forshould
advice. You electronic
not act funds
upon thetransfer or
information
foreign
contained in this currency
publication exchange
without obtaining transactions
specific less than
professional advice. USD 5,000,
The application and ofif laws
and impact a signed
can varysignature
widely basedcard forspecific
on the an account with No
facts involved. therepresentation
institution oralso exists
warranty for
(express
suchastransactions
to the accuracy or completeness
over USD5,000. of the No
information contained inisthis
due diligence publication,
required forand,
cashto the extent permitted
transactions ofbyless
law, than
USD5,000 (other LLP,than
its members,
when twoemployees and
or more
transactions
publication or for totalling
any decision based on it. more than USD5,000 are believed to be linked).
A9. Individuals: The regulator has defined the basic form each customer should fill out. The requirements surrounding independent verification
or authentication vary according to each customer. Individuals should provide identification, tax payment copy or yearly income certificate.
Legal entities: The regulator has defined the basic form that legal entities should fill out. Legal entities should provide Chamber of
Commerce registration, details of partners with shares greater than 5% and tax payments certificate.
A10. There is no need for copies to be certified by a notary (this was a requirement previously). Banks compare the copy with the original
identification when the customer brings in the required documentation.
A11. Customers should be able to demonstrate the source of income and ownership by way of a copy of a tax payment, income certificate etc.
Banks should monitor changes in income or properties of their clients, where information is available.
A12. Banks should comply with the minimum requirements of the regulations, which include special additional tasks for Politically Exposed
Persons (PEPs). Reduced requirements apply to persons or companies that operate with significant cash amounts as a result of the
business they are in. The bank should perform detailed due diligence so future controls can be omitted. There are some cases which
customers do not need to fill out the form e.g. special insurance types, multilateral organisms, retirement fund managers and deposit
accounts with a simplified process.
A13. Enhanced due diligence is required for PEPs. In Colombia, this includes not only politically-related people but also publicly recognised
people. This also includes due diligence of deposit accounts which will be used by political parties and during political campaigns.
A14. There are regulatory requirements in relation to PEPs. In Colombia, a PEP is defined as a publicly relevant person (not only politicians).
Each time a PEP is identified, additional due diligence has to be performed, especially when the client manages public resources.
A15. For correspondent banking relationships, every international transaction should be reported to the authorities. Each report requires
information on the origin of the money i.e. client, address, telephone number, activity and reason for sending the wire and beneficiary.
A16. No - but some banks try to avoid relationships with offshore banks.
A17. Entities must define special procedures in order to perform KYC for non face-to-face interviews. They must also implement follow up
procedures for clients transactions.
.
Reporting
Reporting
To whom are Suspicious Activity Reports (SARs) made? Please include a link to their website.
Q18. Financial
A18. Information and Analysis Unit (UIAF) of Colombia - www.uiaf.gov.co
A18. Financial Information and Analysis Unit (UIAF) of Colombia - www.uiaf.gov.co
2010 7,796 SARs (UIAF)
2010(in
GDP 7,796 SARs
current (UIAF)
prices):
*
2010results
This USD288,189 million
in a ratio of 1 SAR(Source: data.worldbank.org
for every )
USD40 million of GDP.
This results in a ratio of 1 SAR for every USD40 million of GDP.
threshold,
Yes, international
financial institutionswire transfers,
should report other transactions
individual etc.?
cash transactions above USD10,000, total monthly cash transactions above USD25,000.
A20.
A20. Yes, financial institutions should report individual cash transactions above USD10,000, total monthly cash transactions above USD25,000.
A21. See Q20
A21. See Q20
A22. Special requirements and an investigation from the regulator shall be performed at an institution that does not report required periodical
AML information.
A22. Special requirements and an investigation from the regulator shall be performed at an institution that does not report required periodical
AML information.
A23. No, each entity is free to develop or use their specific methodology to perform transaction monitoring.
A23. No, each entity is free to develop or use their specific methodology to perform transaction monitoring.
A24. No, each entity shall define if a suspicious transaction shall be continued or not, although it has to be reported to the UIAF.
A24. No, each entity shall define if a suspicious transaction shall be continued or not, although it has to be reported to the UIAF.
A25. Entities monitor all transactions regardless of the entitys jurisdiction.
A25. Entities monitor all transactions regardless of the entitys jurisdiction.
domestic
* GDP atcurrencies
purchaser's using single
prices year
is the sum official exchange
of gross rates. by
value added Foralla resident
few countries whereinthe
producers theofficial
economy exchange
plus any rate does not
product reflect
taxes and the rateany
minus effectively
subsidies applied to actual
not included in foreign exchange
the value transactions,
of the products. It is an
alternative
calculated conversion factordeductions
without making is used. for depreciation of fabricated assets or for depletion and degradation of natural resources. Data are in current U.S. dollars. Dollar figures for GDP are converted from
. domestic currencies using single year official exchange rates. For a few countries where the official exchange rate does not reflect the rate effectively applied to actual foreign exchange transactions, an
This publication
alternative has been
conversion prepared
factor for general guidance on matters of interest for the personal use of the reader, and does not constitute professional advice. You should not act upon the information
is used.
contained
. in this publication without obtaining specific professional advice. The application and impact of laws can vary widely based on the specific facts involved. No representation or warranty (express
or implied)
This is given
publication asbeen
has to theprepared
accuracyfororgeneral
completeness
guidance of on
thematters
information contained
of interest in this
for the publication,
personal use of and, to the extent
the reader, and doespermitted by law, PricewaterhouseCoopers
not constitute professional advice. You shouldLLP, itsnot
members,
act uponemployees and
the information
agents do not
contained accept
in this or assume
publication any obtaining
without liability, responsibility
specific or duty ofadvice.
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PwC helps care and
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any consequences
application
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No representation
countries with more in this (express
thanor180,000
warranty
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or implied) or
is for anyasdecision
given based onorit.completeness of the information contained in this publication, and, to the extent permitted by law, PricewaterhouseCoopers LLP, its members, employees and
to the accuracy people who are committed to delivering quality in assurance, tax and advisory services. Tell us what matters to you and find out more by visiting us at
www.pwc.com.
of which
This publication is ahas
separate and independent
been prepared legal
for general

or duty of care for any consequences of you or anyone else acting, or refraining to act, in reliance on the information contained in this
guidance
PricewaterhouseCoopers International Limited, to each
the information
the of which isor
accuracy a completeness
refers to the
network
without of member
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legal entity.
of the information
firmsprofessional
specific of

advice. No representation or warranty (express or implied) is given as
contained in this publication, and, to the extent permitted by law, PwC does do not accept or assume
Cayman Islands
Cayman Islands
Key contact:
Key contact: Charles
Charles Bolland
Bolland Postal address:
Postal address: P.
P. O.
O. Box
Box 258
258 Last updated:
Last updated:
Email: charles.bolland@ky.pwc.com
Email: charles.bolland@ky.pwc.com Strathvale House; 90 North Church Street
Strathvale House; 90 North Church Street January 2013
January 2013
Tel: +1345
Tel: +1345 914
914 8610
8610 George Town; Grand Cayman
George Town; Grand Cayman
Cayman Islands
Cayman Islands KY1-1104
KY1-1104
General
General
Q1.
Q1.
Inwhat
In whatyear
yeardid
didthe
therelevant
relevantAML
AMLlaws
lawsand
andregulations
regulationsbecome
becomeeffective?
effective?
A1.
A1.
1996.However
1996. Howeverthe
(theProceeds
Proceedsof
theProceeds
Proceedsof
ofCriminal
ofCrime
CriminalConduct)
CrimeLaw,
Conduct)in
Law,enacted
inorder
enactedinto
ordertotobring
intolegislation
legislationininSeptember
bringharmonisation
harmonisationwith
September2008,
withall
allother
2008,repealed
otherlaws
lawsthat
repealedthe
thatcould
theprevious
previousAnti
couldencompass
encompassmoney
AntiMoney
MoneyLaundering
LaunderingLaw
moneylaundering.
laundering.
Law
(the
Additionally,and
Additionally, andasasaaresult
resultof
ofthe
theintroduction
introductionofofthe
theProceeds
Proceedsof ofCrime
CrimeLaw,Law,the
theMoney
MoneyLaundering
LaunderingRegulations
Regulations(2009
(2009revision)
revision)and
andthe
the
GuidanceNotes
Guidance Noteson
onthe
thePrevention
Prevention&&Detection
DetectionofofMoney
MoneyLaundering
Launderingin inthe
theCayman
CaymanIslands
Islands(March
(March2010
2010revision)
revision)were
werealso
alsoamended.
amended.
Q2.
Q2. IfIfthe
theAML
AMLlaws
lawsand/or
and/orregulations
regulationsbecame
becameeffective
effectivein
inthe
thelast
last22years,
years,what
whatwere
werethe
therequirements
requirementsof
ofthe
theprevious
previousAML
AMLregime?
regime?
A2.
A2.
N/A
N/A
Q3.
Q3.
Whoisisthe
Who theregulator
etc.).Please
regulatorfor
Pleaseinclude
forAML
includelink
AMLcontrols
linkto
tothe
controlsfor:
for:(a)
theregulator(s)
(a)Banking;
Banking;(b)
regulator(s)website
website
(b)Other
Otherfinancial
financialServices;
Services;(c)
(c)Non
Nonfinancial
financialsector
sector(e.g.
(e.g.casinos,
casinos,high
highvalue
valuegoods
goods
etc.).
A3.
A3.
Theregulator
The regulatorfor
forAML
AMLcontrols
controlsisisthe
theCayman
CaymanIslands
IslandsMonetary
MonetaryAuthority
Authority(CIMA)
(CIMA)
Q4.
Q4.
Isthere
Is thereany
anypractical
practicalguidance
locallegislation?
guidanceprovided
legislation?Please
Pleaseinclude
providedto
includelink
linkto
tofirms
firmsby
towebsite,
bypublic
publicauthorities
website,where
authoritiesregarding
whereavailable.
available.
regardingAML
AMLrequirements,
requirements,beyond
beyondthe
theFATF
FATFrecommendations
recommendationsand
and
local
A4.
A4.
Yes,CIMA
Yes, CIMAhas
whichcan
hasissued
canbe
issuedGuidance
befound
foundat
GuidanceNotes
Noteson
on Prevention
Preventionand
andDetection
Detectionof
ofMoney
MoneyLaundering
Launderingand
at http://www.cimoney.com.ky/AML_CFT/aml_cft.aspx?id=144
http://www.cimoney.com.ky/AML_CFT/aml_cft.aspx?id=144
andTerrorist
TerroristFinancing
Financing(the
(theGuidance
GuidanceNotes)
Notes)
which
Q5.
Q5.
Isthere
Is thereaarequirement
requirementto
toretrospectively
retrospectivelyverify
verifythe
theidentity
identityof
ofcustomers
customersbefore
beforethe
thedate
datethe
thenew
newAML
AMLregime
regimewas
wasintroduced?
introduced?
A5.
A5.
Yes
Yes
Q6.
Q6.
Isaarisk
Is riskbased
basedapproach
approachapproved
approvedby
bythe
thelocal
localregulator(s)?
regulator(s)?
A6.
A6.
Yes--aarisk
Yes riskbased
Notesthat
basedapproach
thataarisk
approachisisfacilitated
riskbased,
based,rather
facilitatedboth
ratherthan
thanaa'tick
bothby
'tickbox'
byway
wayof
ofcertain
box'approach,
certainexemptions
approach,should
exemptionsfor
shouldbe
beadopted.
forparticular
adopted.
particularproducts,
products,and
andexplanation
explanationwithin
withinthe
theGuidance
Guidance
Notes
Q7.
Q7.
Hasthe
Has thecountry
pleasefind
countrybeen
findaalink
beenthe
linkto
thesubject
subjectof
toaarelevant
ofaaFATF
relevantreport
report(if
FATF(or(orFATF-style)
(ifpublicly
FATF-style)Mutual
publiclyavailable).
available).
MutualEvaluation
Evaluationor
orIMF
IMFassessment
assessmentexercise
exercisein
inthe
thelast
lastthree
threeyears?
years?IfIfyes,
yes,
please
A7.
A7. Thecountry
The countrywas
wassubject
subjectto
toan
anIMF
IMFinspection
inspectionin
in2009:
2009: http://www.cimoney.com.ky/ext_coop_assess/eca.aspx?id=180
http://www.cimoney.com.ky/ext_coop_assess/eca.aspx?id=180
Customer due
diligence
Q8.
Q8.
Arethere
Are thereminimum
minimumtransaction
transactionthresholds,
thresholds,under
underwhich
whichcustomer
customerdue
duediligence
diligenceisisnot
notrequired?
required?
IfIfYes,
Yes,what
whatare
arethe
thevarious
variousthresholds
thresholdsin
inplace?
place?
A8.
A8.
Yes--one-off
Yes one-offtransactions
transactionsof
ofless
lessthan
thanKYD15,000.
KYD15,000.
..
Thispublication
publicationhashasbeen
beenprepared
preparedfor forgeneral
generalguidance
guidanceon onmatters
mattersofofinterest
interestfor
forthe
thepersonal
personaluse useofofthe
thereader,
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anddoes
doesnot
notconstitute
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professionaladvice.
advice.You
Youshould
shouldnot
notact
actupon
uponthe
theinformation
information
This
containedininthis
thispublication
publicationwithout
withoutobtaining
obtainingspecific
specificprofessional
professionaladvice.
advice.The
Theapplication
applicationand andimpact
impactofoflaws
lawscancanvary
varywidely
widelybased
basedon onthe
thespecific
specificfacts
factsinvolved.
involved.No
Norepresentation
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(express
contained
agents
2013 do
PwC.not accept
All rights or assume
reserved. any
Not liability,
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of PwC. PwC of you
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to anyone
the else
network ofacting,
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PricewaterhouseCoopers the information
International contained
Limited in this
(PwCIL), or, as the
publication
context orfor
requires,forindividual
anydecision
decision based
member onit.it.
firms of the PwC network. Each member firm is a separate legal entity and does not act as agent of PwCIL or any other member firm. PwCIL does not provide any services
publication or any based on
to clients.
2009
responsible
PwCIL is not responsible or
2009PricewaterhouseCoopers.
PricewaterhouseCoopers.
or liable for the International
liable
rightsfor
Allrights
acts or All
omissions
Limited,
International Limited,
the actsPricewaterhouseCoopers
reserved.
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A6. Yes - a risk based approach is facilitated both by way of certain exemptions for particular products, and explanation within the Guidance
Notes that a risk based, rather than a 'tick box' approach, should be adopted.


A7. by
Country Thecountry
country was subject to anof
comparison IMF inspection
high in 2009:Your
level Know http://www.cimoney.com.ky/ext_coop_assess/eca.aspx?id=180
Customer and Anti-Money Laundering information
A8. Yes - one-off transactions of less than KYD15,000.
.
Q9. What
contained in this are the
publication high
without level specific
obtaining requirements foradvice.
professional verification of customer
The application and impactidentification
of laws can varyinformation
widely based on(individuals andinvolved.
the specific facts legal entities)?
No representation or warranty (express
A9. Individuals:
publication or for certified
any decision based
funds and understanding
on it. photo identification (usually passport); verification of residential address (driving licence or utility bill etc.); source of
of source of wealth.
Corporates: must identify the company, its directors and beneficial owners of 10% or more of the company's holdings. Company items such
as Memorandum and Articles of Association, Certificate of Incorporation, register of members, directors and officers, authorised signatory
lists, financial statements etc. are required on acceptance of new business. Further, due diligence on at least two directors and due
diligence on beneficial owners of greater than 10% as described for individuals or 'natural persons' as above.
A10. Documents must be originals, notarised or certified copies. Examples of suitable certifiers are lawyers, accountants, notary publics or civil
servants.
A11. All beneficial owners of 10% or greater of a company's holdings must be identified/verified. Beneficial owners below 10% should be
identified if the entity appears structured to avoid this requirement. Note that certain entities are exempt, such as those listed on a
recognised stock exchange.
A12. Reduced /simplified due diligence requirements exist for the following scenarios. Key exemptions include:
a) non paying accounts, effectively covering mutual fund investments if the funds can only be returned to the beneficial owner from
which they came;
b) regulated financial institutions in certain jurisdictions listed in Schedule III of the Regulations;
c) potentially any circumstance in which a full eligible introducers form is used (and the party relying on the eligible introducer form
remains liable for any failure of the person making the introduction to obtain and record satisfactory evidence of the identity of the
third party);
d) listed institutions on certain specified exchanges and their subsidiaries (evidence must be provided for use of exemption); and
e) certain other bodies, for example governmental bodies and pension funds for professional associations.
A13. Local guidance includes information on enhanced due diligence for Politically Exposed Persons ('PEPs'), high risk countries or other higher
risk businesses, such as not for profit associations (including charities).
A14. Local guidance requires senior management approval, reasonable measures to establish source of wealth and funds and enhanced
ongoing monitoring.
A15. No enhanced due diligence measures required for regulated correspondent banking relationships (see also response to Q16 below).
A16. The Money Laundering Regulations (2009) have been amended to state that no person conducting relevant financial business should form
a business relationship or carry out a one-off transaction, with any institution that has no physical presence in the territory in which it is
incorporated or in which it is carrying on such business and is unaffiliated with a regulated financial group that is subject to consolidated
supervision. Further clarification on correspondent banking relationships with shell banks is provided in the Money Laundering Guidance
Notes.
A13. Local guidance includes information on enhanced due diligence for Politically Exposed Persons ('PEPs'), high risk countries or other higher
risk businesses, such as not for profit associations (including charities).

Know
A14.
Local guidance requires senior management approval, reasonable measures to establish source of wealth and funds and enhanced
ongoing monitoring.
A15. No enhanced due diligence measures required for regulated correspondent banking relationships (see also response to Q16 below).
A16. The Money Laundering Regulations (2009) have been amended to state that no person conducting relevant financial business should form
a business relationship or carry out a one-off transaction, with any institution that has no physical presence in the territory in which it is
incorporated or in which it is carrying on such business and is unaffiliated with a regulated financial group that is subject to consolidated
supervision. Further clarification on correspondent banking relationships with shell banks is provided in the Money Laundering Guidance
Notes.
.
Q17.
This publicationInhas
what
beencircumstances
prepared for general is guidance
additional due diligence
on matters required
of interest for foruse
the personal non face-to-face
of the transactions
reader, and does not constituteand/or relationships?
professional advice. You should not act upon the information
A17. In response
agents do not accept or assumetoany
a recommendation
liability, responsibility orfrom
the
duty of careCFATF during theirof2007
for any consequences you or evaluation of the
anyone else acting, Caymanto Islands
or refraining
Guidance Notes on Money Laundering have been amended to indicate that financial institutions should have policies and procedures in
money
act, in reliance on thelaundering regime,in the
information contained this
place to address All any
rightsspecific
risks associated withrefers to the network of business
non-face-to-face member firmsrelationships
of
or transactions.
Reporting
A18. The Money Laundering Regulations require that Suspicious Activity Reports are made to the Financial Reporting Authority (the FRA):
http://www.fra.gov.ky
2011 406 SARs (FRA)
A20. Other than SARs, payment service providers are required to report to the FRA if they restrict or terminate business relationships with its
payee service providers due to the payee service provider regularly supplying insufficient information on the payee.
A21. See above response to question 8 on the KYD15,000 exemption.
A22. Yes, per section 139 of the Proceeds of Crime Law, a person is guilty of an offence if they know or suspect that a report is about to, or has
been made and discloses to any other person information which is likely to prejudice an investigation punishable under the law by a
maximum prison term of 5 years, an unlimited fine or both.
A23. While the use of automated mechanisms to monitor suspicious transactions is suggested by the Guidance Notes as best practice, it is
recognized that this may not be cost effective for all companies. As such there is no legal or regulatory requirement to use automated
suspicious transaction monitoring technology.
A21. See above response to question 8 on the KYD15,000 exemption.
Know
Yes, per section 139 of the Proceeds of Crime Law, a person is guilty of an offence if they know or suspect that a report is about to, or has
been made and discloses to any other person information which is likely to prejudice an investigation punishable under the law by a
maximum prison term of 5 years, an unlimited fine or both.
A23. While the use of automated mechanisms to monitor suspicious transactions is suggested by the Guidance Notes as best practice, it is
recognized that this may not be cost effective for all companies. As such there is no legal or regulatory requirement to use automated
suspicious transaction monitoring technology.
A24. There is no requirement to obtain authorisation from the FRA to proceed with a current/ongoing transaction that is identified as suspicious
unless criminal proceedings have commenced and the matter becomes subject to the Attorney Generals direction and a resulting freeze
order. In that case, direction would be required from the AG (Attorney General) prior to proceeding with the transaction.
.
Q25. Does
contained in this the local
publication withoutlegislation allow
obtaining specific transactions
Thebeapplication
monitored outside
and impact thecan
of laws jurisdiction?
vary widely based on the specific facts involved. No representation or warranty (express
A25. There is no explicit direction in local legislation on monitoring transactions outside the jurisdiction. However the Guidance Notes do
recognize parent/subsidiary
2009 PricewaterhouseCoopers. All rights reserved.relations and also customer
PricewaterhouseCoopers refers to transactions for their
firmsown
account and makes allowance for minimized KYC
the network of member
of
procedures when such transactions occur in countries with equivalent legislation as the Cayman Islands (also known as Schedule 3

countries).
www.pwc.com.
Canada
Key contact: Gino Soave Postal address: Last updated:
Email: gino.soave@ca.pwc.com 18 York Street, Suite 2600 January 2013
Tel: +1 416 687-8760 Toronto, Ontario, M5J 0B2, Canada
General
A1. Proceeds of Crime (Money Laundering) and Terrorist Financing Act (PCMLTFA) was passed in 2000, and amended 2001, 2006, 2008 and
2010.
A2. N/A. Note, pursuant to findings from the 2008 Mutual Evaluation and the statutory review of the PCMLTFA, the Minister of Finance has
introduced consultation papers on proposed changes to legislation intended to bring Canadas AML/ATF regime in line with FATF
Recommendations.
A3. In 2001, the Financial Transactions Reports Analysis Centre of Canada (FINTRAC) was established under the PCMLTFA to serve as
Canadas financial intelligence unit. FINTRAC is responsible for ensuring compliance with AML/AFT requirements by all Reporting Entities,
including financial entities (banks, trust companies, credit unions, etc.), life insurance companies, securities dealers (including asset
managers/investment advisers), casinos, dealers in precious metals and stones, real estate agents and certain developers, accountants and
notaries public based in the province of British Columbia.
The Office of the Superintendent of Financial Institutions (OSFI), established in 1987, is the federal agency responsible for the supervision
and regulation of all federally incorporated or registered banks, life insurance companies, property and casualty insurance companies, and
federally regulated private pension plans.
The Canadian Securities Administrators (CSA) is an umbrella organization comprised of 13 provincial and territorial securities regulatory
authorities, The CSA serves as a forum for coordinating and harmonizing the regulation of Canadian capital markets. Securities regulators
also delegate certain aspects of securities regulation to self-regulatory organizations including the Investment Industry Regulatory
Organization of Canada (IIROC).
FINTRAC and OSFI report to the federal Minister of Finance.
FINTRAC has in place MOUs (Memoranda of Understanding) with both OSFI and IIROC, but does not delegate its supervisory role through
MOUs to other regulators. Information obtained by other regulators through their own supervisory activities, including examinations, is
provided to FINTRAC under the MOU and is taken into consideration by FINTRAC during its risk assessment process. In addition to the
audits and examinations performed by the regulators under their own supervisory framework, the results of which, with respect to AML/CFT
relevant issues are provided to FINTRAC, FINTRAC conducts examinations in each sector, whether or not it is covered by an MOU. In fact,
FINTRAC has conducted examinations in every sector covered by the PCMLTFA with the exception of financial institutions supervised by
OSFI since FINTRAC fully relies on OSFI to conduct AML/AFT compliance initiatives.
http://www.fintrac.gc.ca/
http://www.iiroc.ca/Pages/default.aspx
http://www.osfi-bsif.gc.ca/osfi/index_e.aspx?ArticleID=3
.
2013 PwC.
accept reserved.
assume Not
consequences refers
you to
or the network
context requires,
on it.
network
exercise of member
of another firms of
member
MOUs to other regulators. Information obtained by other regulators through their own supervisory activities, including examinations, is
provided to FINTRAC under the MOU and is taken into consideration by FINTRAC during its risk assessment process. In addition to the
audits and examinations performed by the regulators under their own supervisory framework, the results of which, with respect to AML/CFT
relevant issues are provided to FINTRAC, FINTRAC conducts examinations in each sector, whether or not it is covered by an MOU. In fact,
FINTRAC has conducted examinations in every sector covered by the PCMLTFA with the exception of financial institutions supervised by
OSFI since FINTRAC fully relies on OSFI to conduct AML/AFT compliance initiatives.
http://www.fintrac.gc.ca/

http://www.iiroc.ca/Pages/default.aspx
http://www.osfi-bsif.gc.ca/osfi/index_e.aspx?ArticleID=3
A4. FINTRAC has published plain language interpretations and guidelines as well as interpretation notices
http://www.fintrac.gc.ca/publications/pub-eng.asp and FINTRAC Guidelines - FINTRAC - Financial Transactions and Reports Analysis
Centre of Canada
OSFI Guideline B-8: Deterring and Detecting Money Laundering was issued in December 2008.-
http://www.osfi-bsif.gc.ca/app/DocRepository/1/eng/guidelines/sound/guidelines/b8_e.pdf
.
This publicationIIROC issued
has been Anti-Money
prepared Laundering
for general guidance Compliance
on matters of interest for Guidance in October
the personal use 2010-
of the reader, and does not constitute professional advice. You should not act upon the information
http://docs.iiroc.ca/DisplayDocument.aspx?DocumentID=6279890DECD84244A8E38F8A23E80E4A&Language=en
Q5. Is there a requirement to retrospectively verify the identity of customers before the
date the new AML regime was introduced?
A5. No, however pursuant to the adoption of a Risk Based Approach to ML/TF governance, customers considered to be a higher ML/TF risk are
required to be identified.
A6. Yes - firms are required to assess and document the risk related to money laundering and terrorist activity financing in their business. This
assessment must be tailored and should consider factors such as customers and business relationships, products, delivery channels and
geographic areas where business is conducted, as well as other relevant factors.
A7. FATF released its third evaluation of Canada in February 2008:

http://www.fatf-gafi.org/dataoecd/5/3/40323928.pdf
A8. Customer identification is not required for:

a) Electronic Funds Transfer (EFT) transactions less than CAD1,000 or foreign currency exchange transactions less than CAD3,000.
This exception also holds true in the case where a signed signature card for an account with the institution also exists for
transactions over these thresholds.
b) Cash transactions less than CAD10, 000 (other than when two or more transactions aggregate to more than CAD10,000 and are
believed to be related).
A9. Individuals: Reporting Entities must obtain, verify and maintain the following records of an individuals identity: customer name, date of
birth, address, the nature of the customers principal business or occupation and intended use of the account. Regulations state that the
identity of a person should be ascertained by referring to a birth certificate, driving licence, provincial health insurance card, passport or any
similar record.
Legal entities: a reporting entity must confirm the existence of any legal entity for which it opens a business account by obtaining such
legal documentation as Articles of Incorporation, Articles of Association, Partnership Agreement or other similar record. The record used to
confirm the corporations existence can be in paper or electronic format. If the record is an electronic version, firms must keep a record of
the corporations registration number, the type and source of the record. Furthermore, depending on legal entity type, additional
documentation may be required. For example, in the case of a corporation, the name of the corporations directors and the name, address
and principal occupation of all individuals who directly or indirectly own or control 25% of more of the shares of the corporation, must also be
obtained, The identity of up to 3 individuals authorized to transact on behalf of the legal entity must also be verified as well as evidence to
support those individuals authorization to transact on behalf of the legal entity.
.
A10. It is acceptable for a reporting entity to rely on the customer identification records of an affiliate or co-member when the customer is not
physically present. In this case, the reporting entity must obtain the name, address and date of birth of the individual from the affiliate.
Customer identification through attestation is also permitted, in which case confirmation must be obtained to demonstrate that the
customers ID has been certified to be true and correct by a commissioner of oaths or a guarantor. The attestation method requires that the
document is a legible photocopy and contains the name, profession, address and signature of the commissioner of oaths or the guarantor,
and the type and number of the identifying document. This method can only be used in conjunction with other prescribed methods of
customer identification, including referring to an independent and reliable identification product or cleared cheque or deposit account.
In order for a document to be acceptable for identification purposes, it must be valid (i.e. not expired), have a unique identifier number and
issued by a provincial, territorial or federal government.
A11. When a firm has to identify an entity, it must take reasonable measures to obtain and keep a record of information relating to the entitys
beneficial ownership. For a corporation, this includes the name and occupation of all directors and the name, address and occupation of all
individuals who own or control 25% or more of the shares of the corporation. If the information cannot be obtained, a record must be
maintained explaining why beneficial ownership could not be determined.
A12. s.62 of the PCMLTF Regulations provides certain exemptions allowing for reduced/simplified due diligence. These include:
a) public bodies;
b) corporations (and any consolidated subsidiaries) with minimum net assets of CAD75 million on its last audited balance sheet and
whose shares are traded on a Canadian stock exchange or a stock exchange that is prescribed by section 3201 of the Income
Tax Regulations and operates in a country that is a member of the Financial Action Task Force;
c) regulated entities such as pension funds, financial entities, securities dealers, investment funds and life insurance companies
d) Simplified due diligence is also permitted with respect to certain products/services, including credit card accounts, and in the
purchase of registered annuity policies or income funds.
Q13. In what circumstances is enhanced customer due diligence measures required?
A13. A firm's compliance program must include the development and application of policies and procedures to assess the risk of a money
laundering offence or a terrorist activity financing offence. Special measures should be taken in high risk situations for identifying customers
and monitoring transactions. When a risk assessment determines that risk is high for money laundering or terrorist financing, policies and
procedures to keep customer identification information up to date must be developed. For a financial entity, a securities dealer, a life
insurance company, broker or agent, or a money services business, this also applies to keeping beneficial ownership information up to date.
This information should be reviewed at a minimum at least every two years.
OSFI Guidance states that federally regulated firms that conduct business in offshore jurisdictions or that have customers that operate in
those jurisdictions, need to be especially vigilant. Certain customers may merit additional due diligence, and examples given include
businesses that handle large amounts of cash or those that hold important public positions.
A14. When dealing with PEPs, the following additional due diligence measures must be taken:
enhanced account monitoring; senior management approval to maintain the account or senior management review of transaction within 14
days of account activation or EFT transaction; and reasonable measures to obtain source of funds.
A15. The following due diligence requirements are required for correspondent banking relationships: obtaining personal information about the
foreign entity and its activities; ensuring that the foreign entity is not a shell bank; obtaining the approval of senior management; and setting
out in writing the firm's obligations and those of the foreign entity in respect of the correspondent banking services.
.
A16. Yes.
A17. Recent amendments have introduced a broader and more flexible set of identification requirements related to non-face-to-face transactions.
The new requirements set out the following two options for identification of individuals not physically present:
a) Confirmation from an affiliated entity and verification of the name, address, telephone number and date of birth record;
b) Combination of two of the following methods: referring to an independent identification product or, with the individuals
permission, referring to a credit file; obtaining an attestation concerning an identification document for the individual from a
Commissioner of Oaths or a guarantor; confirming that a cheque drawn on a deposit account with a financial entity (other than
one that is exempt from identification requirements) has cleared; and confirming that the individual has a deposit account with a
financial entity (other than one that is exempt from identification requirements).
Reporting
A18. Suspicious transaction reports (STRs) are filed with FINTRAC:

http://www.fintrac.gc.ca/intro-eng.asp

Between 2007 and 2011, 407,835 STRs, EFTRs, LCTRs, and other reports were received by FINTRAC. Thirty-three percent (approximately
134,586) of those reports were STRs (FINTRAC Typologies and Trends Reports April 2012)
http://www.fintrac-canafe.gc.ca/publications/typologies/2012-04-eng.pdf

Sum of GDP for 2007-2011 inclusive USD7,557,412 million (Source: data.worldbank.org* )
This results in a ratio of 1 STR for every USD56.2 million of GDP.
A20. Yes. Under the PCMLTFA, all reporting entities are required to report to FINTRAC transactions for which they have reasonable grounds to
suspect that the transactions are related to money laundering or terrorist financing (this includes attempted suspicious transactions). In
addition, all reporting entities must report the following transactions to FINTRAC, unless stated otherwise:
a) Large Cash Transactions receipt of an amount of CAD10,000 or more in the course of a single transaction, or multiple
transactions over a 24 hour time period;
b) Electronic Funds Transfers international ingoing and outgoing EFTs valued at CAD10,000 or more in the course of a single
transaction, or multiple transactions in a 24 hour time period by or on behalf of the same individual or entity. This requirement
applies to financial entities, MSBs (Money Service Business) and casinos;
c) Terrorist Property a report must be submitted to FINTRAC if a reporting entity has property in its control or possession that is
owned or controlled by or on behalf of a terrorist, a terrorist group, or listed person (nil reports must also be filed monthly either to
FINTRAC or their principal regulator such as OSFI or IIROC); and
d) Casino Disbursements a casino must file a report when it makes a disbursement valued at CAD10,000 or more in the course of
a single transaction, or over the course of multiple transactions in a 24 hour time period.
.
A17. Recent amendments have introduced a broader and more flexible set of identification requirements related to non-face-to-face transactions.
The new requirements set out the following two options for identification of individuals not physically present:
a) Confirmation from an affiliated entity and verification of the name, address, telephone number and date of birth record;
b) Combination of two of the following methods: referring to an independent identification product or, with the individuals

permission, referring to a credit file; obtaining an attestation concerning an identification document for the individual from a
Commissioner of Oaths or a guarantor; confirming that a cheque drawn on a deposit account with a financial entity (other than
one that is exempt from identification requirements) has cleared; and confirming that the individual has a deposit account with a
financial entity (other than one that is exempt from identification requirements).
Reporting
A21. No. All suspicious transactions and attempted suspicious transactions need to be reported. However, s. 50 of the Regulations allows for
exceptions toSuspicious
reporting Large Cash Transactions (>$10,000) for include
businesses
To whom are
Q18. Industry Classification Activity Reports (SARs) made? Please a linkinto
industries identified in certain sectors of the North American
their website.
System
A18. Suspicious transaction reports (STRs) are filed with FINTRAC:

http://www.fintrac.gc.ca/intro-eng.asp
Are there any penalties for non compliance with reporting requirements e.g. tipping off?
Q22.
A22. Yes. There are criminal or administrative penalties associated with non-compliance with reporting requirements, including tipping off. Both
Q19. What wasand
criminal theadministrative
volume of SARs made to
monetary the authorities
penalties (AMPs)incannot
the most recent year?
be issued againstPlease stateinstance
the same the GDPoffor the equivalent year.
non-compliance. AMPs violations
are classified by the PCMLTF Regulations as Minor, Serious or Very Serious, and carry maximum penalties of CAD1,000, CAD100,000
and CAD500,000 respectively.
FINTRAC2007
Between mayanddisclose
2011,cases of non-compliance
407,835 to law enforcement
STRs, EFTRs, LCTRs, when were
and other reports there received
is extensive non-compliance
by FINTRAC. or littlepercent
Thirty-three expectation of
(approximately
immediate
134,586) of or future
those compliance.
reports Criminal
were STRs penalties
(FINTRAC may include
Typologies and the Reports April 2012)
following:
Trends
a) Failure to report suspicious transactions: up to CAD2 million and/or 5 years imprisonment.
http://www.fintrac-canafe.gc.ca/publications/typologies/2012-04-eng.pdf
b) Failure to report a large cash transaction or an electronic funds transfer: up to CAD500,000 for the first offence, CAD1 million for
subsequent
GDP (in current prices):offences.
Sum of c) GDP
Failure to meet record
for 2007-2011 inclusive USD7,557,412
keeping requirements:million
up to (Source:
CAD500,000 and/or 5 years*imprisonment.
data.worldbank.org )
d) Failure to provide assistance or provide information during compliance examination: up to CAD500,000 and/or 5 years
This resultsimprisonment.
in a ratio of 1 STR for every USD56.2 million of GDP.
e) Disclosing the fact that a suspicious transaction report was made, or disclosing the contents of such a report, with the intent to
prejudice a criminal investigation: up to 2 years imprisonment.
A20. Yes. Under the PCMLTFA, all reporting entities are required to report to FINTRAC transactions for which they have reasonable grounds to
suspect
No. that the transactions are related to money laundering or terrorist financing (this includes attempted suspicious transactions). In
A23. addition, all reporting entities must report the following transactions to FINTRAC, unless stated otherwise:
a) Large Cash Transactions receipt of an amount of CAD10,000 or more in the course of a single transaction, or multiple
transactions over a 24 hour time period;
b) a Electronic
Is there requirement Funds Transfers
to obtain international
authority to proceed ingoing and outgoing EFTs
with a current/ongoing valued at
transaction CAD10,000
that is identifiedoras
more in the course of a single
suspicious?
Q24. transaction, or multiple transactions in a 24 hour time period by or on behalf of the same individual or entity. This requirement
applies to financial entities, MSBs (Money Service Business) and casinos;
A24. No. c) Terrorist Property a report must be submitted to FINTRAC if a reporting entity has property in its control or possession that is
owned or controlled by or on behalf of a terrorist, a terrorist group, or listed person (nil reports must also be filed monthly either to
FINTRAC or their principal regulator such as OSFI or IIROC); and
d) Casino Disbursements a casino must file a report when it makes a disbursement valued at CAD10,000 or more in the course of
Q25. Does the a single
local transaction,
legislation allowortransactions
over the course
to beof multiple transactions
monitored in a 24 hour time period.
outside the jurisdiction?
A25. Regulations do not specify from/to where transactions must be monitored.
.
people who
does not services.
constitute Tell us what matters
professional advice. to you
You and find
should not out
act more by visiting
upon the us at
information
www.pwc.com.
prepared forin this publication,
ontomatters
the extent permitted
of interest byand
only, law,does
advice. employees
upon
without or anyone
professional advice.toNoact, in reliance onorthe
warranty contained
or implied)

any liability,
which is a or for anyand
separate
of caretofor
decision
theany
based on
independent
consequences
network of member
it. entity.
legal
offirms
you or

Brazil
Key
Key contact:
contact: Alfredo
Alfredo Sneyers
Sneyers and
and Jos
Jos Postal
Postal address:
address: Last
Last updated:
updated:
Barbosa Teixeira
Barbosa Teixeira Centro
Centro Empresarial
Empresarial Agua
Agua Branca,
Branca, January
January 2013
2013
Email:
Email: alfredo.sneyers@br.pwc.com
alfredo.sneyers@br.pwc.com // So Paulo, Brazil
So Paulo, Brazil
Jose.barbosa.teixeira@br.pwc.com
Jose.barbosa.teixeira@br.pwc.com
Tel:
Tel: +55
+55 (0)
(0) 11
11 3674
3674 3686
3686
General
General
Q1. In
In what
what year
year did
did the
the relevant
relevant AML
AML laws
laws and
and regulations
regulations become
become effective?
effective?
Q1.
A1. 1998
1998 (Law
(Law 9.613)
9.613) amended
amended 20022002 byby Law
Law No.
No. 12,683
12,683 of
of July
July 9,
9, 2012,
2012, expanding
expanding its
its impact.
impact. The
The new
new law
law expands
expands the
the range
range of
of illicit
illicit
A1. activities.
activities. Only
Only drug
drug trafficking,
trafficking, terrorism,
terrorism, weapons
weapons smuggling,
smuggling, kidnapping,
kidnapping, crimes
crimes committed
committed by
by criminal
criminal organizations,
organizations, and
and crimes
crimes against
against
the
the public
public administration
administration and
and the
the financial
financial system
system were
were previously
previously listed.
listed.
Q2. IfIf the

the AML
AML laws
laws and/or
and/or regulations
regulations became
became effective
effective in
in the
the last
last 22 years,
years, what
what were
were the
the requirements
requirements of
of the
the previous
previous AML
AML regime?
regime?
Q2.
A2. N/A.
N/A.
A2.
Q3. Who
Who is is the
the regulator
regulator for
for AML
AML controls
controls for:
for: (a)
(a) Banking;
Banking; (b)
(b) Other
Other financial
financial Services;
Services; (c)
(c) Non
Non financial
financial sector
sector (e.g.
(e.g. casinos,
casinos, high
high value
value goods
goods
Q3. etc.).
etc.). Please
Please include
include link
link to
to the
the regulator(s)
regulator(s) website
website
A3. COAF
COAF Conselho
Conselho de
de Controle
Controle das
das Atividades
Atividades Financeiras
Financeiras https://www.coaf.fazenda.gov.br/
https://www.coaf.fazenda.gov.br/
A3.
Q4. Is
Is there
there any
any practical
practical guidance
guidance provided
provided to
to firms
firms by
by public
public authorities
authorities regarding
regarding AML
AML requirements,
requirements, beyond
beyond the
the FATF
FATF recommendations
recommendations and
and
Q4. local
local legislation?
legislation? Please
Please include
include link
link to
to website,
website, where
where available.
available.
A4. Yes
Yes https://www.coaf.fazenda.gov.br/
https://www.coaf.fazenda.gov.br/
A4.
Q5. Is
Is there
there aa requirement
requirement to
to retrospectively
retrospectively verify
verify the
the identity
identity of
of customers
customers before
before the
the date
date the
the new
new AML
AML regime
regime was
was introduced?
introduced?
Q5.
A5. Yes
Yes -- Resolution
Resolution 2025
2025 of
of 2003
2003 establishes
establishes the
the mandatory
mandatory requirements
requirements relating
relating to
to client
client identification
identification when
when opening
opening aa deposit
deposit account.
account.
A5.
Also,
Also, the
the Circular
Circular Nr.
Nr. 3,461
3,461 detailed
detailed how
how financial
financial institutions
institutions should
should put
put these
these policies
policies and
and internal
internal controls
controls into
into practice,
practice, as
as follows:
follows:
a)
a) AML
AML prevention
prevention policies
policies must
must (i) (i) specify
specify the
the responsibilities
responsibilities at at each
each level
level of
of the
the institution;
institution; (ii)
(ii) arrange
arrange for
for timely
timely collection
collection of
of
information
information onon customers;
customers; (iii)
(iii) set
set clear-cut
clear-cut criteria
criteria for
for staff
staff selection
selection and
and monitoring;
monitoring; (iv)
(iv) order
order the
the prior
prior review
review of
of new
new banking
banking
products
products and
and services;
services; and
and (v)
(v) provide
provide for
for full
full in-house
in-house disclosure
disclosure of of such
such policies;
policies; and
and
b)
b) internal
internal controls
controls must
must comprise
comprise prior prior measures
measures aimed
aimed atat (i)
(i) confirming
confirming record
record data
data of
of customers
customers and and end
end beneficiaries;
beneficiaries; and
and (ii)
(ii)
identifying
identifying aa customers
customers status
status as as politically
politically exposed
exposed person
person (PEP);
(PEP); among
among other
other issues.
issues.
Q6. Is
Is aa risk
risk based
based approach
approach approved
approved by
by the
the local
local regulator(s)?
regulator(s)?
Q6.
A6. No.
No.
A6.
Q7. Has
Has the
the country
country been
been thethe subject
subject of
of aa FATF
FATF (or(or FATF-style)
FATF-style) Mutual
Mutual Evaluation
Evaluation or
or IMF
IMF assessment
assessment exercise
exercise in
in the
the last
last three
three years?
years? IfIf yes,
yes,
Q7. please
please find
find aa link
link to
to aa relevant
relevant report
report (if
(if publicly
publicly available).
available).
..
This
This publication
publication hashas been
been prepared
prepared for
for general
general guidance
guidance onon matters
matters of of interest
interest for
for the
the personal
personal use
use of
of the
the reader,
reader, and
and does
does not
not constitute
constitute professional
professional advice.
advice. You
You should
should not
not act
act upon
upon the
the information
information
contained
contained inin this
this publication
publication without
without obtaining
obtaining specific
specific professional
advice. The
The application
application andand impact
impact of of laws
laws can
can vary
vary widely
widely based
based onon the
the specific
specific facts
facts involved.
involved. No
No representation
representation or
or warranty
warranty (express
(express
or
implied)
or 2013 PwC.
implied) is
is given as
as to
All rights
given the
the accuracy
reserved.
to Not foror
accuracy completeness
orfurther of
of the
distribution
completeness information
without
the contained
the permission
information contained of in
in this
PwC. publication,
thisPwC refersand,
publication, to the
and, to the
the extent
to network of permitted
extent by
by law,
member firms
permitted PricewaterhouseCoopers
of PricewaterhouseCoopers
law, LLP,
LLP, its
PricewaterhouseCoopersInternationalits members,
Limitedemployees
members, (PwCIL), or,and
employees as the
and
agents
agents dodo not
not accept
accept or
or assume
assume any liability,
anyfirms
liability, responsibility
responsibility or
or duty
duty of care
care for any
anyisconsequences of
of you
you or anyone else acting, or
or refraining to
to act, in
in reliance on
on the information contained in
in this
context requires, individual member of the PwC network. Eachofmember forfirm consequences
a separate legal entityorand
anyone
doeselse acting,
not act refraining
as agent of PwCIL act,
or any reliance
other memberthefirm.
information contained
PwCIL does this any services
not provide
publication
publication or for any
or for is
any decision based on it.
to clients. PwCIL notdecision based
responsible or on it. for the acts or omissions of any of its member firms nor can it control the exercise of their professional judgment or bind them in any way. No member firm is
liable
responsible
2009
or liable for the acts or omissions
PricewaterhouseCoopers. All
All rights
International
of any other member firm nor can it control
rights reserved.
Limited, eacheach of
PricewaterhouseCoopers refers
of which
which isis aa separate
separate andand independent
the exercise
refers to
to the
the network
independent legal
of another
network of of member
legal entity.
entity.
memberof
member firms
firms of
information on customers; (iii) set clear-cut criteria for staff selection and monitoring; (iv) order the prior review of new banking
products and services; and (v) provide for full in-house disclosure of such policies; and
b) internal controls must comprise prior measures aimed at (i) confirming record data of customers and end beneficiaries; and (ii)
identifying a customers status as politically exposed person (PEP); among other issues.

Know
Is a risk based approach approved by the local regulator(s)?
A6. by No.
A7. The FATF publishes a executive summary of the mutual evaluation report which summarises the anti-money laundering (AML)/combating
the financing of terrorism (CFT) measures in place in the Federative Republic of Brazil (hereinafter Brazil) as of the time of the on-site visit
(26 October to 7 November 2009), and shortly thereafter: http://www.fatf-
gafi.org/topics/mutualevaluations/documents/mutualevaluationreportofbrazil.html
. On March 12, 2012, the Central Bank amended the rules applicable to procedures that must be adopted by financial institutions in the
This publicationprevention and combat
has been prepared for generalofguidance
moneyonlaundering and for
matters of interest terrorism financing,
the personal as a response
use of the reader, and does nottoconstitute
the recommendations of the
professional advice. You Financial
should Action
not act upon Task
the information
Force withoutThe
(FATF). obtaining
main specific professional
measures advice. The application and impact of laws can vary widely based on the specific facts involved. No representation or warranty (express
include:
agents do not accept a) enactment
or assume ofresponsibility
any liability, Circular No. 3,583,
or duty which
of care for anysets forth that
consequences (a) orfinancial
of you institutions
anyone else shall not
acting, or refraining initiate
to act, anyonrelationship
in reliance the informationwith clients,
contained in thisor
proceed
publication or for any decision based onwith
it. existing relationships, if it is not possible to fully identify such clients, and (b) anti-money laundering procedures are
also applicable
b) International
PricewaterhouseCoopers enactment
to agencies
of Circular
Limited,
and subsidiaries
No.is3,584,
each of which
refers of
establishing
a separate
Brazilian
to the
thatlegal
and independent
financial
network of
theentity.
institutions
member firms of located abroad,
institutions authorized to operate in the
Brazilian foreign exchange market
with financial institutions located abroad must verify if the other party is physically present in the country where it was organized
and licensed or is object of effective supervision, and
c) enactment of Letter 17 Circular No. 3,542 (Letter Circular No. 3,542), which increases the list of examples of transactions and
situations which may characterize evidence of occurrence of money laundering, tending to improve the communication between
financial institutions and the Council of Control of Financial Activities (Conselho de Controle de Atividades Financeiras, or
COAF).
A8. Suspected activities or transactions must be reported to the Brazilian financial intelligence unit, Conselho de Controle de Atividades
Financeiras (COAF), in a manner yet to be detailed by the Central Bank. Suspected activities include, among others:
a) actual or proposed issuance or recharge of one or more stored value cards totaling R$ 100 thousand in a given calendar month;
b) actual or proposed cash transactions exceeding R$ 100 thousand;
c) suspected transactions above R$10 thousand (i.e., those involving suspicious parties or values, or without economic reasons,
etc.);
d) transactions apparently intended to sidestep identification mechanisms or controls;
e) actions suspected of financing terrorist activity.
Further, the financial institution must designate to the Central Bank an officer who will be in charge of reports to COAF as well as of
compliance with the measures set out in Circular 3,461.
The Central Bank may mete out the following penalties on non-compliant financial institutions and on their senior management, depending
on the severity of the offense: (a) warning; (b) fine; (c) temporary prohibition from holding a senior management office in financial
institutions; and (d) cancellation of authorization or license to operate.
A9. Individuals: full name, nationality, date and place of birth, address, Identification (type, number, date of emission and emitting institution),
number of inscription on the Cadastro de Pessoa Fsica ('CPF') etc. Full name is to be verified against a local identification document.
Corporations: full name, type and date of constitution, address, documents containing the same information required for individuals who
qualify and authorise the representatives to use the account, number of inscription on the Cadastro Nacional de Pessoa Jurdica ('CNPJ')
etc. Names of legal entities are verified against the Register of Certification (there are also other detailed requirements).
A10. When clients provide copies of identification documentation, they also have to provide the original documents so that the institution can
certify that those copies are valid. There is no information in the regulations or guidance on third party certification.
A11. For insurance entities, the identification information required for beneficial ownership (not required to go up to level of ultimate beneficial
owners) should contain, at a minimum, the information/documentation specified for both individuals and legal entities.
.
A12. The same information is required for all clients, in accordance with the requirements of the Central Bank.
A14. Circular 3,461 from Brazilian Central Bank detailed how financial institutions should put these policies and internal controls into practice,
as follows:
a) AML prevention policies must (i) specify the responsibilities at each level of the institution; (ii) arrange for timely collection of
information on customers; (iii) set clear-cut criteria for staff selection and monitoring; (iv) order the prior review of new banking
products and services; and (v) provide for full in-house disclosure of such policies; and
b) internal controls must comprise prior measures aimed at (i) confirming record data of customers and end beneficiaries; and (ii)
identifying a customers status as politically exposed person (PEP); among other issues.
A15. The main measures include:

a) enactment of Circular No. 3,583, which sets forth that (a) financial institutions shall not initiate any relationship with clients, or
proceed with existing relationships, if it is not possible to fully identify such clients, and (b) anti-money laundering procedures are
also applicable to agencies and subsidiaries of Brazilian financial institutions located abroad,
b) enactment of Circular No. 3,584, establishing that the institutions authorized to operate in the Brazilian foreign exchange market
with financial institutions located abroad must verify if the other party is physically present in the country where it was organized
and licensed or is object of effective supervision, and
c) enactment of Letter 17 Circular No. 3,542 (Letter Circular No. 3,542), which increases the list of examples of transactions and
situations which may characterize evidence of occurrence of money laundering, tending to improve the communication between
financial institutions and the Council of Control of Financial Activities (Conselho de Controle de Atividades Financeiras, or
COAF).
A16. No - although they are not prohibited, they are closely monitored.
Reporting
A18. COAF Conselho de Controle de Atividades Financeiras www.coaf.fazenda.gov.br

. Approximately 1 million SARs per year for the last 2 years.
Q20. Are there
or assume obligations to reportoranything
liability, responsibility duty of caremore
for anythan suspicious
consequences of youtransactions e.g. unusual
or anyone else acting, transactions,
or refraining cash
to act, in reliance transactions
on the abovein athis
information contained certain
Yes. All kind of suspicious activities must be reported to COAF.

A20.
Know
A19.
Volume of SARs:
Approximately
Country by 1 million SARsof
country comparison perhigh
year level
for theKnow
last 2 years.
Your Customer and Anti-Money Laundering information
A20. Yes. All kind of suspicious activities must be reported to COAF.
A21. Yes, for activities below BRL5,000 (approx USD3,000).
A22. Yes - the area of Supervision of the Central Bank of Brazil reviews and monitors compliance with very closely.
A23. No.
A24. Yes in some cases, the COAF requests the Bank does not terminate the account or relationship with the client so that the COAF can best
investigate the transactions of a particular customer. In this case all monitoring between the COAF and the Bank is documented.
A25. The bank secrecy law prevents a client's activities being monitored or reported outside the country.
.
who are committed to delivering quality
the network
tax and
of member advisory
firms of

Bolivia
Key contact: Boris Mercado / Vladimir Llanos Postal address: Last updated:
Email: boris.mercado@bo.pwc.com / Ed. Hansa Piso 19, January 2013
vladimir.llanos@bo.pwc.com Av. Mcal. Santa Cruz,
Tel: +591 2-240 8181 La Paz, Bolivia
General
A1. 1997.
A2. N/A.
A3. For the Financial Sector, the Financial System Authority (ASFI) is responsible for analysing suspicious financial activities:
https://www.asfi.gob.bo/
A4. Yes the Financial System Authority (ASFI) provides guidance for external auditors to perform the AML review.
A5. No.
A6. No every financial institution is an independent organisation. Their methodology used to determine whether a risk based approach is used
or not, is their responsibility.
A7. No.
A8. Yes - all transactions below USD10,000 do not require customer due diligence measures. Customers who engage in transactions above this
limit must provide information relating to the transaction to the regulatory body (UIF - Unidad de Investigaciones Financieras).
.
agents
2013 PwC.
do notAllaccept
rights or
reserved.
assumeNot
or dutythe permission
of care for anyof PwC. PwC refers
consequences of youto
orthe network
context requires,
on of
network
exercise of member
member of

A9. The law and its procedures define minimum requirements to identify customers:
Individuals: birth date, nationality, National Identification number (carn de identidad) or passport number, Nmero de Identificacin
Tributaria (NIT) (if applicable, which is the Taxpayers Identification Number), marital status and spouse name (if applicable), home and
business address, telephone number, profession, occupation and commercial references.
Legal entities: Entity name, activity, Nmero de Identificacin Tributaria (NIT) (which is the Taxpayers Identification Number), business
address, telephone number, shareholders list, executives list, commercial references and entity constitution documents.
A10. According to law, financial institutions should always verify original identification documents. However, for legal entities, there are some
documents that can be provided as copies, if those copies are certified by a notary public office.
A11. The following situations require financial institutions to collect additional information about beneficial ownership:
a) when the client informs the institutions that the final beneficiary is another person or entity;
b) when the financial institution has doubts about the final beneficiary;
c) when the customer engages in commercial, financial or industrial transactions in a location where they have no operations;
d) when transactions are greater than USD10,000 or its equivalent in local currency in current accounts, saving accounts, long term
deposits, money exchange, among others; or
e) when the total of multiple linked transactions is an amount greater than USD10,000, or its equivalent in local currency.
A12. Simplified due diligence arrangements are available for transactions below the USD10,000 threshold.
A13. Enhanced due diligence arrangements are required for transactions above the USD10,000 threshold.
A16. No.
Reporting
.
A16. No.

Know
A17.
None stated in local regulations or guidance.
Reporting
.
Q18.
contained in thisTo whom without
publication are Suspicious Activity
obtaining specific Reports
professional (SARs)
advice. made? and
The application Please
impactinclude
of laws cana link to their
vary widely website.
based on the specific facts involved. No representation or warranty (express
A18. Banks and financial

2009 PricewaterhouseCoopers. institutions
All rights prepare periodic reports
reserved. PricewaterhouseCoopers refers to for the UIF
the network of (AML)
member at the
firms of Financial System Authority: https://www.asfi.gob.bo/.

A20. No, except for all transactions above USD10,000.
A21. Yes, below USD10,000.
A22. The regulator establishes the appropriate penalties to be charged according to the degree of non compliance.
A23. No.
A24. The regulator establishes the appropriate procedure for suspicious activities.
A25. For any transaction (remittances, drafts, etc) above USD10,000 the form PCC01 will need to be completed that details origin, reason and
destination for the transaction. In addition, the financial institutions must adhere to the requirements of correspondent banks in cross-border
relationships. However the regulation is silent on whether transactions can be monitored outside the country.
www.pwc.com.
.
This publication
This publication has been prepared for general guidance has been
on matters prepared
of interest forpersonal
for the general guidance
use of theon matters
reader, andofdoes
interest
not only, and does
constitute not constitute
professional advice.professional
You should advice. You should
not act upon not act upon
the information
the information
contained in this publication without obtaining specific contained
professional advice.inThe
thisapplication
publicationandwithout
impact obtaining specific
of laws can vary professional
widely basedadvice.
on the No representation
specific or warranty
facts involved. (express oror
No representation implied) is given
warranty as
(express
to the accuracy
or implied) is given as to the accuracy or completeness or completeness
of the information containedof the information
in this contained
publication, in this
and, to the publication,
extent permittedand, to the
by law, extent permitted by law,LLP,
PricewaterhouseCoopers PwCitsdoes do notemployees
members, accept or assume
and
any liability,orresponsibility
agents do not accept or assume any liability, responsibility duty of care or
forduty
any of care for any consequences
consequences of you or anyone of else
you or anyone
acting, else acting,
or refraining or refraining
to act, to on
in reliance act,the
in information
reliance on contained
the information
in thiscontained
publication or for any decision based on it. in this publication or for any decision based on it.
Argentina
Key contact: Karin Reise Postal address: Bouchard 557 - P.7; Last updated:
Email: karin.reise@ar.pwc.com C1106ABG; Ciudad de Buenos Aires; January 2013
Tel: +54 11 4850 6818 Argentina
General
A1. 1996.
A2. N/A.
A3. UIF: Unidad de Informacin Financiera for a), b) and c) www.uif.gov.ar .
Also for banking a) the BCRA (Central Bank of Argentina) have additional requirements. www.bcra.gov.ar .
A4. On the website www.uif.gov.ar there is information and guides. e.g. http://www.uif.gov.ar/uif/index.php/es/sobre-el-lavado-de-activos .
A5. No.
A6. Yes - although local regulators require certain procedures to be performed without taking into account the risk profile of the transaction or
customer.
A7. Yes http://www.fatf-gafi.org/topics/mutualevaluations/documents/mutualevaluationofargentina.html
A8. No.
.
2009 PricewaterhouseCoopers. of any other
to the of another
network
member
of member firms firms
of

A9. The law established two types of customers: 'permanent' and 'not frequent'. For each type of customer specific documentation is required,
which varies from a simple identification to a tax declaration. Names are verified against original documents for both individuals and entities.
'Not frequent' customers who are individuals need to provide: full name, birth place and date, citizenship, etc. Entities must provide: name,
identification number, Tax identification number, Constitution Act and date, etc. Legal officers and shareholders must provide the same
information. 'Permanent' customers in addition need to provide: information on sources of income and financial information of
accounts/investments in other financial entities. All information must be supported by proper documentation.
A10. There is no information on independent verification of documentation in local guidance. This is because original documents must be seen by
financial institutions.
A11. The same as 'permanent' clients, therefore beneficial ownership must be identified.
A12. Firms are not allowed to avoid the identification requirements in connection with the KYC regulations. For 'not frequent' customers a
reduced level of due diligence is allowed.
A13. Enhanced due diligence procedures are required for transactions over USD 10,000 and some additional information is required for
'permanent' customers (see A9 above).
A14. The banking regulation has a specific paragraph on PEPs, requiring special attention to be taken in such cases. For all individuals
considered to be PEPs the KYC regulations apply, including enhanced due diligence regarding volumes and in accordance with the client's
profile.
A16. No.
A17. Based on regulations issued by the Unidad Informacion Financiera, additional due diligence for non face-to-face transactions and/or
relationships is required. Clients must provide information verified by other entities (for example credit card companies and other banks).
Reporting
A18. UIF: www.uif.gov.ar

.
What as was
to the the
accuracy or completeness
volume of SARs of the information
made contained in this
to the authorities publication,
in the most and, to the
recent extent Please
year? permitted state
by law,the
GDP for the equivalent LLP, its members,
year. employees and
Q19.

2011 11,087
All rights reserved. PricewaterhouseCoopers refers to the network of member firms of
SARs
International (source:
Limited, each ofhttp://www.uif.gov.ar/uif/images/links/Informe-de-gestin-2011.pdf
which is a separate and independent legal entity. page 72)
*

2011 11,087 SARs (source: http://www.uif.gov.ar/uif/images/links/Informe-de-gestin-2011.pdf page 72)

This
UIF: results in a ratio of 1 SAR for every USD4.2 million of GDP.
www.uif.gov.ar
Country
Q20. Are
Whatthere
wasany
the obligations to report
volume of SARs madeanything
to the more than suspicious
authorities in the mosttransactions
recent year?e.g. unusual
Please statetransactions,
the GDP for cash transactions
the equivalent above a certain
year.

A20. Yes, in certain circumstances dependent on the industry, there are monthly reports of normal transactions.
2011 11,087 SARs (source: http://www.uif.gov.ar/uif/images/links/Informe-de-gestin-2011.pdf page 72)

*
2011there
Are USD46,710 millionthresholds
any de-minimis (Source: data.worldbank.org )
below which transactions do not need to be reported?
Q21.
A21. ARP50,000 (approximately USD10,000).
threshold,
Are international
there any penalties wire transfers,
for non otherwith
compliance transactions
reportingetc.?
requirements e.g. tipping off?
Q22.
A20. Yes, in certain circumstances dependent on the industry, there are monthly reports of normal transactions.
Yes.
A22.
A21.
A23. ItARP50,000 (approximately
is suggested USD10,000).
in the regulations but not mandatory.
Q22. Are
Is there
there any penaltiestofor
a requirement non compliance
obtain authority to with reporting
proceed with arequirements e.g.transaction
current/ongoing tipping off?that is identified as suspicious?
Q24.
A22. Yes.
No.
A24.
Q23. Are there

Does any requirements
the local (legal
legislation allow or regulatory)
transactions to betomonitored
use automated Suspicious
outside Transaction monitoring technology?
the jurisdiction?
Q25.
A25.
A23. No.
It is suggested in the regulations but not mandatory.
A24. No.
A25. No.
*
.
*
.
www.pwc.com.
Questions and
Questions andAnswers:
Answers:
Know Your
Know Your Customer
Customer quick
quick reference
reference guide
guide
Country by
Country by country
country comparison
comparison of
of high
high level
level Know
Know Your
Your Customer
Customerand
andAnti-Money
Laundering information
information
Vietnam
Key contact: Annett Perschmann-Taubert Postal address: Last updated:
Email: annett.ingrid.perschmann@vn.pwc.com 4th Floor, Saigon Tower, 29 Le Duan Street January 2013
Tel: +84 (8) 3823 0796 ext. 1519 District 1, Ho Chi Minh City, Vietnam
General
A1. Criminal Law issued in 1999 (effective on 1 July 2000)

Law No. 37/2009/QH12 amending and supplementing some articles of the Criminal Law issued in1999) issued in 2009 (effective on 1
January 2010)
Law on Credit Institutions issued in 2010 (effective on 1 January 2011)
Law on anti-money laundering No. 07/2012/QH13 issued in 2012 (effective on 1 January 2013)
A2. N/A. It is the first time regulations on anti-money laundering have been issued in the form of a law.
A3. Anti-Money Laundering Information Centre under the State Bank of Vietnam (SBV): http://www.sbv.gov.vn
A4. No. However the SBV has issued guidance to credit institutions in relation to the installation and use of TRAML programme:
http://www.sbv.gov.vn
A5. No. The Law on anti-money laundering however requests clients information must be updated regularly.
A6. Yes.
A7. The assessment body APG performed an assessment in 2009 - http://www.apgml.org/documents/default.aspx?DocumentCategoryID=17 .
exercise
of member
of another firms of
member

A6. Yes.
Questions
Q7. Has anda linkAnswers:
the country been the subject of a FATF (or FATF-style) Mutual Evaluation or IMF assessment exercise in the last three years? If yes,
please find to a relevant report (if publicly available).
Know
A7.
The assessment body APG performed an assessment in 2009 - http://www.apgml.org/documents/default.aspx?DocumentCategoryID=17 .
Q8. IfbyYes,
Country
Are there minimum transaction thresholds, under which customer due diligence is not required?
country comparison
what are of high level
the various thresholds Know Your Customer and Anti-Money Laundering information
in place?
A8. Financial institutions must verify clients information in certain circumstances such as: when clients open accounts, make transactions of
high value, make suspicious transactions or if there is any doubt regarding the clients identification information.
Certain non-financial institutions are required to identify customers:

a) Casino/gaming businesses;
b) Real estate management or property services companies, if brokerage services in relation to purchase, sale and management of
properties is provided;
c) International
PricewaterhouseCoopers OrganisationsLimited, trading in precious
each of which metals
is a separate and gemstones
and independent
legal entity.if they carry out transactions in relation to purchase/sale of precious
metals/gemstones with large value of cash;
d) Notaries, accounting and legal services companies, if they carry out certain transactions, such as e.g. if they act on their
customers behalf to make transactions, such as transfer of land use rights, or management of customers bank accounts.
e) Organisations providing trust services if they carry out certain transactions, such as providing services such as establishment of
companies.
A9. Article 9 of the Law on anti-money laundering stipulates that the clients information must include:
a) For individual Vietnamese clients: full name, date of birth, nationality, occupation, position; phone number, identity card number or
passport number, date and place of issue and permanent/current address
b) For individual foreign clients: full name, date of birth, nationality, occupation, position; passport number, date and place of issue,
visa, overseas/Vietnam address;
c) For corporate clients: full and abbreviated trading name, address of head office, phone number, fax number, areas of operations
and business, information on the founder and representatives;
d) Information regarding beneficiary. In case of corporate beneficiary: information regarding ownership and control rights.
A10. Article 11 of the Law on anti-money laundering allows engagement of other organisations to conduct the verification.
A11. Under Article 9.2 of the Law on anti-money laundering, it is required to verify the beneficial ownership and apply necessary measures in
order to know and update information of beneficial ownership. For corporate clients, it is required to collect information on ownership and
control structure to determine the individual with the controlling interest and who has the control of the corporate.
A14. Article 13 of the Law on anti-money laundering requests financial/specified non-financial institutions to have internal systems to control
account opening/transactions with foreign PEPs (including their related persons) and to take measures to identify sources of clients assets
and to enhance monitoring business relationship/transactions with clients.
.

Know
Questions
A14. Your
and Customer quick reference guide
Answers:
Article 13 of the Law on anti-money laundering requests financial/specified non-financial institutions to have internal systems to control
account opening/transactions with foreign PEPs (including their related persons) and to take measures to identify sources of clients assets
andcountry
Country by to enhance monitoring business
comparison of highrelationship/transactions
level Know Your Customerwith clients.and Anti-Money Laundering information
A15. Article 14 of the Law on anti-money laundering requests to conduct the following measures upon establishment of agent bank relationships:
a) Collecting information about the banking partner to fully know the nature of business, the partner bank's reputation and ensure the
partner bank must be subject to supervision and management of the foreign competent management agencies;
b) Assessing the implementation of measures on prevention of money laundering of the partner bank;
c) Must be approved by the General Director (Director) or authorisation persons before setting up the banking agent relations;
d) In case the partner banks clients can make payment through the partner banks accounts opened at the institutions, the
.
institutions
This publication has been prepared must
for general ensure
guidance the partner
on matters bank
of interest have
for the fullyuse
personal implemented thedoes
of the reader, and identification, updated the
not constitute professional client
advice. You information andthe
should not act upon that they
information
contained in this publication are able
without to provide
obtaining specific client identification
professional information
advice. The application and as required
impact by vary
of laws can thewidely
institutions.
Q16. Are relationships

2009 PricewaterhouseCoopers. with reserved.
All rights shell banks specifically prohibited?
A16. Not mentioned in the regulations.
A17. Not specifically mentioned in the regulations. However the Law on anti-money laundering refers in Article 17 to business through
introduction by a third party.
Reporting
A18. State Bank of Vietnam: http://www.sbv.gov.vn/wps/portal/vn
A20. Under the Law on anti-money laundering, in addition to suspicious transactions, the following transactions should be reported:
a) high value transactions (level of value to be stipulated by the Prime Minister);
b) electronic money transfer with value exceeding the threshold stated by the SBV;
c) individuals bring currency/gemstones/valuable papers exceeding the threshold stated by the SBV.
A21. Yes, values below the stipulated values as set out in A20.
A22. Yes, penalties for administrative violations.
A23. No. The Law on anti-money laundering however requires the reporting entity to exercise special supervision of certain transactions, such as
transactions with high value or transactions with individuals in countries or territories included in the list published by FATF.
.
A20. Under the Law on anti-money laundering, in addition to suspicious transactions, the following transactions should be reported:
a) high value transactions (level of value to be stipulated by the Prime Minister);
b) electronic money transfer with value exceeding the threshold stated by the SBV;
c) individuals bring currency/gemstones/valuable papers exceeding the threshold stated by the SBV.

Know
Country
Yes, values below the stipulated values as set out in A20.
A22. Yes, penalties for administrative violations.

Know
No. The Law on anti-money laundering however requires the reporting entity to exercise special supervision of certain transactions, such as
transactions with high value or transactions with individuals in countries or territories included in the list published by FATF.
.Q24. Is there a requirement to obtain authority to proceed with a current/ongoing transaction that is identified as suspicious?
A24. No. The Law on anti-money laundering requests the related institutions to delay the suspicious transaction and reports immediately to the
authorities.
Q25. Does theInternational
PricewaterhouseCoopers local legislation allow
Limited, each transactions
of which toand
is a separate beindependent
monitoredlegal outside
entity. the jurisdiction?
A25. No.
www.pwc.com.
Questions and
Answers:
Know Your
Know YourCustomer
Customer quick reference
reference guide
guide
Countryby
Country bycountry
country comparison
comparison of
of high
high level
level Know
Know Your
Your Customer
Customer and
and Anti-Money
information
Thailand
Key contact: Vorapong Sutanont Postal address: Last updated:
Email: vorapong.sutanont@th.pwc.com 15th Floor, Bangkok City Tower; January 2013
Tel: +66 2344 1429 179/74-80 South Sathorn Road;
Bangkok 10120; Thailand
General
A1. 1999.
A2. N/A.
A3. The Anti-Money Laundering Office (the AMLO), please refer to the following website; http://www.amlo.go.th
A4. Yes, please refer to the following website, i.e., http://www.amlo.go.th/amlofarm/farm/en/files/MR_1(1).pdf and
http://www.amlo.go.th/amlofarm/farm/en/files/MR_2(2).pdf
A5. No.
A6. Yes.
A7. No, please refer to the last report issued since 24 July 2007 at the following website;
http://www.amlo.go.th/amlofarm/farm/en/files/DAR_thai.pdf, http://www.apgml.org/documents/docs/17/Thailand%20DAR.pdf and
http://www.imf.org/external/np/pp/eng/2011/051111.pdf.
exercise
of member
member of

Know
A7.
No, please refer to the last report issued since 24 July 2007 at the following website;
http://www.amlo.go.th/amlofarm/farm/en/files/DAR_thai.pdf, http://www.apgml.org/documents/docs/17/Thailand%20DAR.pdf and
http://www.imf.org/external/np/pp/eng/2011/051111.pdf.
Q8. by
Country Arecountry
there minimum transaction
comparison ofthresholds,
high levelunder
Knowwhich customer
Your
due diligence
Customer is not required?
and Anti-Money Laundering information
A8. Non-Financial Institutions: Customer due diligence needs to be performed for new clients on-boarding by designated non-financial
businesses and professions per Section 20/1 of AML Law as amended B.E. 2553 and Ministerial Regulation Prescribing Rules and
Procedures for Customer Due Diligence B.E. 2555 (2012).
Financial Institution: In line with Know Your Customer guidance, customer due diligence needs to be performed for new clients on-
boarding by the financial institution as well as for all existing customers where it has not been performed previously, regardless of the
transaction.
Covered entities: Under Know Your Customer guidance: Banks (including state-owned banks), finance companies, securities dealers,
insurance companies,
businessesInternational
money PricewaterhouseCoopers
Limited, each
or car dealers,
exchanges and remitters,
of which is aagents/brokers,
real-estate
refers toasset
antique
management
the network
legalshops,
companies,
of member firms of

jewellery and gold shops, automotive hire-purchase
entity. personal loan businesses, electronic card and credit-card businesses,
electronic payment businesses, and deposit/lending cooperatives and traders that are not financial institutions engaging in business
involving the operation of, or the consultancy or the provision of advisory services in a transaction relating to the investment or mobilisation
of capital under the law on securities and stock exchange.
A9. Individuals: Institutions should verify the original identification documents; i.e., identity card, passport, household registration book, full
name and other document details.
Legal entities: Institutions should obtain company registration documents as well as examining the type of business, the sources of high
value transactions or unusual characteristics or those that are not related to the business of the customers. Institutions shall examine and
verify the following identification information and evidence of the following persons associated with such juristic person or legal
arrangement: (1) the person authorized to establish a business relationship; (2) the director authorized to conduct a transaction on behalf of
the juristic person or legal arrangement; and (3) the ultimate beneficial owner of the juristic person or legal arrangement (per Ministerial
Regulation Prescribing Rules and Procedures for Customer Due Diligence B.E. 2555 (2012) effective from 22 August 2012).
The institution should maintain copies of verified identification documents for a period of five years.
A10. Financial institutions and designated non-financial businesses and professions shall verify customer identification during the first transaction
and periodically perform review until the account is closed or the relationship is terminated. The verification shall be completed with
professional care, good faith and without gross negligence. Using an alias is not permitted.
In general, where copies of identification documents are provided, such copies shall normally be verified as true and correct by the owner of
the document and/or by verification against the original. Where foreign documents are provided, certification by a public notary and
authentication by the embassy of the country that the document is originally issued, may be required.
A11. Institutions should verify and maintain the power of attorney of beneficial owners from the customer who is conducting the transaction.
A12. Any transaction made by the following parties including king, queen, prince, princess of Thailand, government, state-owned enterprise,
public organisation or other government agencies, foundation, etc., may be reduced or exempted as the Minister deems fit. [Refer to
Ministerial Regulation No.5/2533].
.
A11. Institutions should verify and maintain the power of attorney of beneficial owners from the customer who is conducting the transaction.

Know
Questions
A12. Your
Answers:
Any transaction made by the following parties including king, queen, prince, princess of Thailand, government, state-owned enterprise,
public organisation or other government agencies, foundation, etc., may be reduced or exempted as the Minister deems fit. [Refer to
Ministerial
Country by country Regulation No.5/2533].
comparison of high level Know Your Customer and Anti-Money Laundering information
A13. Enhanced customer due diligence measures are required when the transaction is complex, unusually large, the source of a transaction is
unclear or there is an unusual pattern of transactions that have no apparent or visible economic or lawful purpose. Furthermore, the
institution should enhance ongoing customer due diligence if transactions are suspected to be money laundering related, and for any
customer suspected to be linked with a money laundering offence or terrorism.
Per recent Ministerial Regulation Prescribing Rules and Procedures for Customer Due Diligence B.E. 2555 (2012), the enhanced customer
due diligence required if;
a) the customer is associated with a member of a terrorist group designated by a resolution or notification of the United Nations
Security Council for which the Government of Thailand adopted, or is a person or member of a group of persons who was
. identified as having an involvement in money laundering or terrorism under the law of another country;
b) prepared
This publication has been the customer
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agents do not accept c) the any
or assume customer is or was or
liability, responsibility a duty
person who
of care committed
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of you or anyone or money
else acting, laundering
or refraining to act, inoffense
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associated with a person
information contained in this who
committed
publication or for any decision based on it. a predicate offense or money laundering offense;
d) the customer
e) International
the customer
is a politically
Limited,resides
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theforeign
where
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legalthe
country;
member firms of

international standards for anti-money laundering and counter financing of
entity.
terrorism have not been implemented or applied;
f) the customer has a source of income from a country or territory where the international standards for anti-money laundering and
counter financing of terrorism have not been implemented or applied;
g) the customer engages in a profession which poses a risk of possible connection with money laundering as prescribed by the
Secretary-General with approval of the Board; and
h) the customer is designated by notification of the Secretary-General.
A14. Any transactions made by PEPs require additional due diligence.
A15. Institutions should establish appropriate policies and procedures that include guidance for correspondent banks by enhancing procedures
and paying special attention to high value, complicated and suspicious transactions. In addition, any illegal transactions or transactions with
an unreasonable purpose require enhanced due diligence.
A16. No.
A17. Institutions should establish risk mitigating procedures and measures for account openings for non face-to-face customers and should have
effective monitoring procedures as stringent as those for customers who are physically present.
Reporting
A18. The Director of AMLO

http://www.amlo.go.th/
.
Reporting
Questions
Q18. To whomand Answers:
are Suspicious Activity Reports (SARs) made? Please include a link to their website.
Know Your
Questions and
A18. Customer quick reference guide
Answers:
The Director of AMLO

http://www.amlo.go.th/

2009 1,380,564 SARs (AMLO) ( Noted: This is only latest information available in the AMLO thus not updated)

. This results in a ratio of 1 SAR for every USD190,868 of GDP.

threshold, international
2009 PricewaterhouseCoopers. wire transfers,
All rights reserved. other transactions
PricewaterhouseCoopers refers to etc.?
the network of member firms of
A20. Yes - The financial institution shall have the duty to report the transaction to the Office when it appears that such transaction is:
a) a transaction funded by an amount of cash equal or more than THB2 million . Except in the case of electronic fund transferred
transaction, the financial institution shall have the duty to report if the transaction is equal or more than THB100,000;
b) a transaction connected with the property worth equal or more than THB5 million. Except in the case of movable property
involving electronic fund transfer or payments, the financial institution shall have the duty to report if the transaction is equal or
more than THB700,000; or
c) a suspicious transaction, whether or not it is the transaction under a) or b) or not.
A Land Office of Bangkok Metropolitan, Changwad Land Office, Branch Land Office and Amphoe Land Office shall report to the Office when
it appears that an application is made for registration of a right and judicial act related to an immovable property to which a financial
institution is not a party and which is of any of the following descriptions:
a) requiring cash payment in an amount of cash equal or more than THB2 million
b) involving an immovable property worth equal or more than THB5 million, except in the case of a transfer by succession to a
statutory heir; or
c) being made in connection with a suspicious transaction.
The following designated non-financial businesses and professions shall have the duty to report the transaction to the Office when it
appears that such transaction is funded by an amount of cash equal or more than THB2 million:
a) trader that is not a financial institution, engaging in the business involving the operation of or the consultancy or the provision of
advisory service in a transaction relating to the investment or mobilisation of capital under the law on securities and stock
exchange;
b) trader dealing in the business of gems, diamonds, coloured stones, gold, or ornaments decorated with gems, diamonds, coloured
stones, gold;
c) trader dealing in the business of selling or leasing of cars;
d) trader dealing in the business of immovable property broker or agent;
e) trader dealing in the business of antiques trade under the law on Control of Sale by Auction and Antique Trade; or
f) trader dealing in the business of credit card that is not a financial institution under the Notification of the Ministry of Finance
determining on credit card or the law on financial institution business.
The following designated non-financial businesses shall have the duty to report that transaction to the Office when it appears that such
transaction is funded by an amount of cash equal or more than THB500,000:
a) trader dealing in the business of personal loan under supervision for businesses that is not a financial institution under the
Notification of the Ministry of Finance determining on Personal Loan Businesses under Supervision or under the law on financial
institution business.
The following designated non-financial businesses shall have the duty to report that transaction to the Office when it appears that such
a) trader dealing in the business of electronic money card that is not a financial institution under the Notification of the Ministry of
Finance determining on electronic money card or the law on financial institution business; or
b) trader dealing in the business of electronic payment service under the law on the supervision of electronic payment service
business.
A21. Yes, see 20 above.
.
a) trader dealing in the business of personal loan under supervision for businesses that is not a financial institution under the
A Land Office of Bangkok
Notification of theMetropolitan, Changwad
Ministry of Finance Land Office,
determining Branch Land
on Personal LoanOffice and Amphoe
Businesses Land Office or
under Supervision shall report
under thetolaw
theonOffice when
financial
it appears institution
that an application
business.is made for registration of a right and judicial act related to an immovable property to which a financial
institution is not a party and which is of any of the following descriptions:
a) requiring
The following cash payment
designated in anbusinesses
non-financial amount of shall
cash have
equalthe or more than
duty to THB2
report thatmillion
transaction to the Office when it appears that such
Questions and Answers:b) involving
transaction is funded
statutory
anby immovable
heir; or
an amountproperty
of cash worth
equal equal
or more or more than THB5 million, except in the case of a transfer by succession to a
than THB100,000:

c) beingFinance made in connection
determining with a suspicious
on electronic money card transaction.
or the law on financial institution business; or
The following designated non-financial businesses and professions shall have the duty to report the transaction to the Office when it
business.
Country by country
appears comparison
that such transactionof is high
fundedlevel
by anKnow
amountYour of cashCustomer
equal or more andthanAnti-Money
THB2 million: Laundering information
a) trader that is not a financial institution, engaging in the business involving the operation of or the consultancy or the provision of
advisory service in a transaction relating to the investment or mobilisation of capital under the law on securities and stock
Q21. Are there
Questions and Answers: any de-minimis thresholds below which transactions do not need to be reported?
exchange;
b) trader dealing in the business of gems, diamonds, coloured stones, gold, or ornaments decorated with gems, diamonds, coloured

A21. Yes, c) see 20 stones,
above. gold;
trader dealing in the business of selling or leasing of cars;
d) trader dealing in the business of immovable property broker or agent;
Country by country e) trader dealing in theofbusiness
comparison high levelof antiques
Knowtrade YourunderCustomerthe law onand Control of Sale by Auction
Anti-Money Laundering and Antique Trade; or
information
Q22. Are there f) any
traderpenalties
dealingfor nonbusiness
in the compliance with reporting
of credit card thatrequirements
is not a financial e.g.institution
tipping off? under the Notification of the Ministry of Finance
determining on credit card or the law on financial institution business.
A22. exceeding
Yes, any
The following
person who violates or does not comply with the AMLA regarding reporting and client identification shall be liable to a fine of not
designatedand
THB500,000 non-financial
a daily finebusinesses
not exceeding shallTHB5,000
have the duty to report
through that transaction
the period of violation to or the
untilOffice
actingwhen it appears that such
in accordance.
domestic currencies a) single
Any person
using traderyeardealing
who reports in the
or makes
official exchange business
a For
rates. of personal
notification
a few countries loantheunder
by where
presenting supervision
false
official statements
exchange for businesses
rate does of
notfact
reflectorthe thateffectively
concealing
rate is nottheaapplied
financial
facts institution
to required
actual beunder
toexchange
foreign the to thean
revealed
transactions,
alternative conversion factorNotification
is used. ofbe
theliable
Ministry of Finance determining on exceeding
Personal Loan Businesses under Supervision or under the law orontofinancial
.
competent official shall to imprisonment for a term not two years or to a fine of THB50,000 to THB500,000 both.
institution business.
Theas
or implied) is given following
any designated
to the accuracy non-financial
or completeness businesses
of the information containedshall
in thishave the duty
publication, tothe
and, to report
extent that transaction
permitted to the technology?
Office whenLLP,
by law, PricewaterhouseCoopers it appears that
its members, such and
employees
Q23. Are there
transaction is
requirements
funded by an
(legal
amount
or regulatory)
of cash equal
to use
or more
automated
than
Suspicious
THB100,000:
Transaction monitoring
A23. No.
Finance Limited,
PricewaterhouseCoopers International determining on electronic
each of which is a separatemoney card orlegal
and independent the entity.
law on financial institution
business; or

business.
A24.
Q21.
No.
A21. Yes, see 20 above.

A25.
Q22.
No.
.
www.pwc.com.
.
Questions and
Answers:
Know Your
Know Your Customer
Customer quick
quick reference
reference guide
guide
Country by
Country by country
country comparison
comparison of
of high
high level
levelKnow
KnowYour
Your Customer
Customerand
andAnti-Money
information
Taiwan
Key contact: Eric Tsai Postal address: Last updated:
Email: eric.tsai@tw.pwc.com 27F, 333 Keelung Road, Section 1 January 2013
Tel: +886 2 2729 6687 Taipei, Taiwan 110
General
A1. Taiwan's anti-money laundering legislation is embodied in The Money Laundering Control Act, 1996 (amended in 2003, 2006, 2007, 2008,
and 2009). In 2012, the Executive Yuan made a publication to announce that the Financial Supervisory Commission of Executive Yuan,
which is responsible for the matters listed in Paragraph 2, Article 10 of the Money Laundering Control Act, shall be changed into Financial
Supervisory Commission. The major provisions of the Money Laundering Control Act include a list of predicate offences for money
laundering, customer identification and record keeping requirements, disclosure of suspicious transactions, international cooperation, and
the creation of a financial intelligence unit, the Anti-Money Laundering Division, Investigation Bureau, Ministry of Justice.
A2. N/A
A3. There is no single unified rule-making, supervisory and enforcement government AML body in Taiwan. Different jobs related to AML are
handled by different authorities, such as:
a) The Financial Supervisory Commission is in charge of adopting AML rules for financial institutions and for ongoing supervision.
b) For AML issues concerning wire transfers, the Central Bank of Taiwan serves as a co-rule making body along with the Financial
Supervisory Commission.
c) The Anti-Money Laundering Prevent Center of the Ministry of Justice, which serves as the financial intelligence unit of Taiwan, is
in charge of receiving and compiling money laundering reports.
d) The prosecutors and courts are responsible for the prosecution of money laundering crimes.
A4. Practical guidance is provided to financial institutions, including banks, credit cooperative associations, credit departments of farmers
(fishermens) associations, securities brokers, life insurance companies and futures brokers. The website of the practical guidance is at
http://www.mjib.gov.tw/mlpc/notice.htm
A5. No - however, financial institutions are required to re-validate a customers identification, after the customer has opened an account, if one
of the following conditions is met:
a) the account is opened upon request for a third party;
b) the financial institution becomes suspicious about the activities of the customer; or
c) the customer opened the account by mail.
A6. Yes.
A7. Taiwan has not been the subject of a FATF Mutual Evaluation since 2008.
With respect to the IMF assessment, Taiwan was the subject of the IMF Working Paper - A Quantitative Assessment of Financial
Conditions in Asia dated July 2011. (http://www.imf.org/external/pubs/ft/wp/2011/wp11170.pdf)
exercise
of of member
another firms of
member

A5. No - however, financial institutions are required to re-validate a customers identification, after the customer has opened an account, if one
of the following conditions is met:
a) the account is opened upon request for a third party;
b) the financial institution becomes suspicious about the activities of the customer; or
c) the customer opened the account by mail.
Know
Yes.
Country
Questions and
please find Answers:
a link to a relevant report (if publicly available).
Know
Taiwan has not been the subject of a FATF Mutual Evaluation since 2008.
With respect to the IMF assessment, Taiwan was the subject of the IMF Working Paper - A Quantitative Assessment of Financial
Conditions in Asia dated July 2011. (http://www.imf.org/external/pubs/ft/wp/2011/wp11170.pdf)
A8. Before a financial institution accepts a request of opening account, the financial institution is required to obtain two types of identification and
to keep copies irrespective of transaction amounts.
However, with respect to the currency transactions carried out after the account is opened, the financial institutions referred to in the Money
Laundering Control Act shall ascertain the identity of customer and keep the transaction records as evidence, and submit the financial
transaction, the customers identity and the transaction records to the Investigation Bureau, Ministry of Justice, for any currency transaction
exceeding a certain amount of money (the Minimum Transaction Threshold).
The Minimum Transaction Threshold and the scope of the financial transaction, the procedures for ascertaining the identity of the customer,
and the method and length of time for keeping the transaction records as evidence shall all be established by the central competent
authorities governing target business in consultation with the Ministry of Justice and the Central Bank of the Republic of China.
For banks, credit cooperative associations, credit departments of farmers (fishermens) associations, securities brokers and life insurance
companies, the Minimum Transaction Threshold is TWD500,000 (or the equivalent in foreign currency).
A9. Individuals: Where an individual applies to open an account, the teller shall, other than his/her identity card, obtain other document(s)
which could verify his/her identity e.g. National Health Insurance Card, passport, driving license, student identity card, household registry
book or household registry certificate. The teller should, at the same time, check with the Joint Credit Information Centre (JCIC) or conduct
an enquiry through the Banks own database on whether the individual is a political celebrity in other countries. If yes, the teller should
enforce proper control measures and conduct regular reviews on the account.
Legal entities: Where a non-individual applies to open an account, the teller shall obtain certificates verifying incorporation registration,
official documents or other supporting certificates and shall, in addition, obtain the minutes of its Board of Directors meeting, Articles of
Incorporation or financial statements before approving the application to open an account. The registration license for incorporation of the
company, if any, may serve to be the non-individual account representative's (or responsible persons) secondary identification certificates.
In the case of opening an account for a company, if the companys registration license has been collected and the search and recording of
the companys registration has been conducted by a financial organization, it is not necessary to request the minutes of directors' meetings.
A10. Original forms of identification are necessary as photocopies are not accepted.
A11. Financial institutions are required to exercise extraordinary diligence if the transaction of a customer meets, among other things, the
situations where the end beneficiary or transaction counterparty is found to be a terrorist individual or entity as advised by a foreign
government via the Financial Supervisory Commission, deemed by an international AML institution, or based on reasonable doubts.

A10. Original forms of identification are necessary as photocopies are not accepted.
Questions
Q11. What areand Answers:
the high level requirements around beneficial ownership (identification and verification)?
Know
Questions
A11. Your
Answers:
Financial institutions are required to exercise extraordinary diligence if the transaction of a customer meets, among other things, the

situations where the end beneficiary or transaction counterparty is found to be a terrorist individual or entity as advised by a foreign
government
Country by countryvia the Financial of
comparison Supervisory
high levelCommission,
Know Your deemed by an international
Customer AML institution,
and Anti-Money or based information
Laundering on reasonable doubts.
A12. While customer identification verification and record-keeping are still required, banks are exempted from the requirement to report to the
Investigation Bureau, Ministry of Justice for the following transactions (even if the amount is TWD500,000 or larger). However, the identity of
customer shall still be ascertained and the transaction records shall still be kept as evidence:
a) a transaction (whether receivable or payable) conducted by a government entity, government corporation, an entity that exercises
government power (within the consigned scope), a public/private school or a public utility and the funds prove to comply with the
laws and regulations concerned of the government;
b) an inter-bank transaction and fund arrangement: In the event a client of a fellow bank yields a payable amount through an inter-
bank deposit account e.g. honouring a cheque issued by a fellow bank, the case shall still be handled as required if the
transaction of a same client amounts to over the specific amount;
c) the amounts paid by a national lottery dealer;
d) transaction as payment collected for a third party (excluding the transaction in deposit of stock money for an earmarked account)
where the payment note already expressly bears the name, identity Card number (including the code which enables the search of
the identity of the transaction counterpart), category and amount of the transaction. In such a case, nevertheless, a duplicate copy
of the payment note shall be archived to verify the transaction; and
e) in cases of non-individual accounts such as a department store, megastore, supermarket chain, gas station, hospital, clinic,
. transportation entity, hotel, restaurant, which must deposit cash amounting to over the specific amount regularly or routinely in line
with business
This publication has been prepared for general needs,
guidance the Bank,of while
on matters interestverifying the de
for the personal use facto needs,
of the reader, andshall submit
does not theprofessional
constitute name to the Investigation
advice. You should notBureau, Ministry
act upon the of
information
contained in this publication Justice for information.
without obtaining Declaration
specific professional on application
advice. The a case-by-case
and impactbasis
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based on with for such
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involved. Nounless the Investigation
agents do not accept or assumeBureau, Ministry
any liability, of Justice
responsibility responds
or duty on consequences
of care for any the contraryofwithin ten days
you or anyone from receipt
else acting, of to
or refraining theact,name list.on the information contained in this
in reliance
Q13.
In what circumstances is each of which is
enhanced a separate due
customer and independent
diligencelegal entity.
measures required?

A13. a) for any currency transaction exceeding TWD500,000, financial institutions shall ascertain the identity of the customer, keep the
transaction records as evidence and submit the financial transaction, the customers identity and the transaction records to the
Investigation Bureau and the Ministry of Justice.
b) financial institutions are required to conduct enhanced due diligence measures where there is suspicion of money laundering or
other illegal activities and in the case of wealth management customers.
A14. No specific requirements are required for PEPs.
A15. Banks are required to:

a) gather sufficient information about a respondent institution to fully understand the nature of the respondents business and to
determine, from publicly available information, the reputation of the institution and the quality of supervision, including whether it
has been subject to a money laundering or terrorist financing investigation or regulatory action;
b) assess the respondent institutions AML controls, and ascertain that they are adequate and effective;
c) obtain approval from senior management before establishing new correspondent relationships;
d) document the respective AML responsibilities of each institution;
e) where a correspondent relationship involves the maintenance of payablethrough accounts, it is necessary to identify the
correspondent bank has strictly identified the customers identity and be able to provide the relevant identity information if
necessary.
A16. Banks are prohibited from establishing a correspondent relationship with any shell banks or any foreign financial organizations permitting
any shell banks to use their account.
A17. Banks are required to implement procedures that allow them to verify customer identity on non-face-face transactions just as effectively as
they do on transactions conducted in person.
Reporting
.
A16. any shell banks to use their account.
Know
A17.
Questions Your
Banks are required to implement procedures that allow them to verify customer identity on non-face-face transactions just as effectively as
Answers:
they do on transactions conducted in person.

Reporting
.
Q18.
contained in thisTo whom are
publication Suspicious
without Activity
obtaining specific Reports
professional (SARs)
advice. made? and
The application Please
impactinclude a link
of laws can to their
vary widely website.
A18. Financial
publication or for any decisionIntelligence
based on it. Unit (FIU), the Anti-Money Laundering Division, Investigation Bureau, Ministry of Justice:
http://www.mjib.gov.tw/mlpc/download-1.htm.

2011 7,514 SARs deals of suspicious transactions were reported by financial institutions to the Investigation Bureau, Ministry of Justice.
A20. Yes. The items other than suspicious transactions required to be reported are as follows:
a) any currency transaction exceeding a certain amount of money (the Threshold). For banks, credit cooperative associations,
credit departments of farmers (fishermens) associations, securities brokers and life insurance companies, the Threshold is TWD
500,000 (or the equivalent in foreign currency).
b) passengers or service crew on board who cross the border with the carrier and carry the following items shall make declarations
to customs. The customs shall report subsequently to the Investigation Bureau, Ministry of Justice.
a. Cash of foreign currency with total amount exceeding a certain amount.
b. Negotiable securities with a face value exceeding a certain amount.
A21. Yes. Any non-suspicious currency transaction below TWD500,000.
A22. Yes.
a) Any financial institution not reporting any currency transaction exceeding TWD500,000, as required by relevant laws and
regulations, shall be punished by a fine between TWD200,000 and TWD1 million.
b) Any financial institution not reporting any suspicious transaction shall be punished by a fine between TWD200,000 dollars and
TWD1 million. However, if the violating financial institution is able to prove that the cause of such violation is not attributable to the
intentional act or negligent act of its employee(s), no fine shall be imposed.
A23. No.
A24. In respect of the internal controls of a financial institution, any suspicious transaction shall be reported to vice-CEO or the same level
personnel.
A25. Taiwan is a member of the Egmont Group and The Asia/Pacific Group on Money Laundering. Taiwan has cooperated with some countries
to investigate AML matters.
www.pwc.com.
This publication has been prepared for general guidance on matters
the information of interest
contained in thisforpublication
the personal use ofobtaining
without the reader, and does
specific not constitute
professional advice. professional advice. or
No representation You should not
warranty act upon
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contained in this publication without obtaining specific professional
to the accuracy advice. The application
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Questions and
Answers:
Know Your
Know Your Customer
Customer quick
quick reference
reference guide
guide
Countryby
Country by country
country comparison
comparison of
of high
high level
level Know
Know Your
Your Customer
Customer and
and Anti-Money
information
Singapore
Key contact: Kwok Wui San Postal address: Last updated:
Email: wui.san.kwok@sg.pwc.com 8 Cross Street, 17-00 PWC Building, January 2013
Tel: +65 (0) 6236 3087 Singapore, 048424
General
A1. 1993 (amended 1999 and 2006).
A2. N/A.
A3. (a) & (b) AML is regulated by the Monetary Authority of Singapore (MAS). Please refer to link: http://www.mas.gov.sg/en/Regulations-and-
Financial-Stability/Regulatory-and-Supervisory-Framework/Anti-Money-Laundering-and-Countering-the-Financing-of-Terrorism.aspx
(c) AML is regulated by Commercial Affairs Department of Singapore. Please refer to link: http://www.cad.gov.sg/amlcft/stro/
A4. http://www.mas.gov.sg/Regulations-and-Financial-Stability/Regulatory-and-Supervisory-Framework/Anti-Money-Laundering-and-
Countering-the-Financing-of-Terrorism/Notices-and-
Guidelines.aspx?sc_q=finance%20companies&sc_type=Filter%20by%20category&sc_p=1
http://app.cra.gov.sg/public/www/content.aspx?sid=42
http://www.mas.gov.sg/~/media/resource/publications/consult_papers/2012/9%20October%202012%20Designation%20of%20Tax%20Crim
es%20as%20Money%20Laundering%20Predicate%20Offences%20in%20Singapore.pdf (Consultation Paper released for designation of
A5. Yes.
A6. Yes.
A7. Yes. FATF Mutual Evaluation undertaken in February 2008. 2 nd follow-up report was performed in February 2011.
http://www.fatf-gafi.org/media/fatf/documents/reports/mer/FoR%20Singapore.pdf
to the of another
network
member
of

A6.
Know
Yes. FATF Mutual Evaluation undertaken in February 2008. 2 nd follow-up report was performed in February 2011.
http://www.fatf-gafi.org/media/fatf/documents/reports/mer/FoR%20Singapore.pdf
Q8. Are
Country there minimum
by country transaction
comparison ofthresholds,
high levelunder
Knowwhich customer
Your
due diligence
Customer is not required?
A8. Customer due diligence is required. However the extent of due diligence performed may vary based on the risk. For example, in respect of
simplified customer due diligence, the regulation states that a bank may perform such simplified customer due diligence measures as it
considers adequate to effectively identify and verify the identity of the customer, a natural person appointed to act on the customers behalf
and any beneficial owner, if it is satisfied that the risks of money laundering and terrorist financing are low (certain conditions apply).
A9. Requirement to identify and verify customers, natural persons appointed to act on a customers behalf and beneficial owners. This includes
a) verification using reliable, independent sources; and
b) retaining copies of all reference documents used to verify the identity of these persons.
A10. Where the customer provides copies and not original identification documents, financial institutions may consider accepting documents that
are certified to be true copies by qualified persons.
A11. There are requirements to take reasonable measures to understand the ownership and control structure of the customer, and enquire if any
beneficial owner exists in relation to a customer.
Where there is one or more beneficial owner (s) in relation to a customer, the financial institution needs to take reasonable measures to
obtain information sufficient to identify and verify the identities of the beneficial owner (s).
A12. Financial institutions may perform simplified customer due diligence measures it considers adequate to effectively identify and verify the
identity of the customer, a natural person appointed to act on the customers behalf and any beneficial owner, if it is satisfied that the risks of
money laundering and terrorist financing are low.
However simplified customer due diligence arrangements are not allowed in certain circumstances, such as:
a) where the customer originates from or is based in a country/jurisdiction known to have inadequate AML/CFT measures; and/or
b) where the financial institution suspects that money laundering or terrorist financing is involved.
A13. Enhanced customer due diligence measures are required to be taken in situations such as:
a) when dealing with Politically Exposed Persons ('PEPs');
b) when dealing with types of customers, business relations or transactions the financial institution assesses to present a higher risk
for money laundering and terrorist financing; and
c) when dealing with business relations and transactions with any person originating from or based in countries and jurisdictions
known to have inadequate AML/CFT measures.
A14. In all circumstances.
A15. Generally, a bank shall satisfy itself of the money laundering risks and perform the following:
a) assessing the suitability of the respondent bank;
b) documenting the respective AML/CFT responsibilities of each bank; and
c) obtaining approval from the bank's senior management to provide new correspondent banking services.
.
A14. In all circumstances.
Know
A15.
Questions Your
Generally, a bank shall satisfy itself of the money laundering risks and perform the following:
Answers:
a) assessing the suitability of the respondent bank;
b) documenting the respective AML/CFT responsibilities of each bank; and
c) obtaining
Country by country approval from
comparison of highthe bank's
level senior
Knowmanagement
Your Customerto provide
andnew correspondent
Anti-Money banking services.
A16. Prohibited to enter into or continue correspondent banking relations with a shell bank.
.
Q17. In what
or implied) is given as to circumstances is additional
the accuracy or completeness of the due diligence
information required
contained for non face-to-face
in this publication, and, to the extenttransactions and/or
permitted by law, relationships? LLP, its members, employees and
A17. Where there is All

2009 PricewaterhouseCoopers. norights
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Reporting
A18. Suspicious Activity Reports (SARs) are reported to Commercial Affairs Department of Singapore - http://www.cad.gov.sg/amlcft/stro/
A20. Reporting to Commercial Affairs Department of Singapore is made based on unusual transactions and transactions beyond certain
threshold.
A21. There is no de-minimis threshold. The emphasis is on the suspicious nature of the transaction rather than the quantum.
A22. Yes.
A23. No.
A24. Yes. Under the Monetary Authority of Singapore (Anti-Terrorism Measures) Regulations 2002, no financial institution is allowed to deal
direct or indirectly with any person suspected of carrying out terrorism activities unless written approval is obtained from MAS.
A25. Yes but subject to compliance with conditions and restrictions.
www.pwc.com.
professional advice. professional advice. You
No representation should not
or warranty act upon
contained vary
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acting, LLP, its on
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agents do not accept or assume any liability, responsibility or duty of care for any consequences
in this publication or for any decision based on it. of you or anyone else acting, or refraining to act, in reliance on the information contained in this
Questions and
Answers:
Know Your
Know Your Customer
Customer quick
quick reference
reference guide
guide
Country by
Country by country
country comparison
comparison of
of high
high level
level Know
Know Your
Your Customer
Customer and
andAnti-Money
information
South Korea
Key contact: Hee-Chul Jung Postal address: Last updated:
Email: hee-chul.jung@kr.pwc.com/ LS Yongsan Tower, January 2013
hcjung@samil.com 191 Hangangro 2ga,
Tel: + 82 2 3781 9381 Yongsanku, Seoul,
140-702, Korea
General
A1. 2001 (amended 2005, with stricter customer due diligence and money laundering regulations implemented in 2007).
A2. Under the 2005 amendment, responsibility for customer due diligence and filing of Cash Transaction Reports (CTRs) was imposed.
Customer due diligence has been self-controlled by each financial institution and is now compulsory in the 2007 regulations.
A3. Korea Financial Intelligence Unit (KoFIU, http://www.kofiu.go.kr/) is the regulator for AML for financial institutions.
A4. Yes. KoFIU has been provided guidelines for regional AML Requirements (Link).
A5. Yes - the amendments made in 2007 require entities to retrospectively verify the identity of high risk customers only.
A6. Yes - prior to the 2007 amendments of the AML regulations, a risk based approach to customer due diligence was optional. Under the 2007
amendments, a risk based approach is compulsory and guidelines have been prepared.
A7. Yes in 2009, Korea has been the subject of a FATF Mutual Evaluation. Relevant report is available at the FATF Website (Link).
A8. The minimum thresholds for occasional transactions under which customer due diligence is not required are as follows:
- USD 5,000 or equivalent in the case of a transaction in a foreign currency; and
- KRW 10,000,000.
Transactions less than KRW 10,000,000 should be aggregated over a certain period. If the aggregated amount exceeds this threshold,
customer due diligence should be conducted.
to the of another
network
member
of member

firms of
A6. Yes - prior to the 2007 amendments of the AML regulations, a risk based approach to customer due diligence was optional. Under the 2007
amendments, a risk based approach is compulsory and guidelines have been prepared.
Questions
Q7. Has and Answers:
Know
A7.
Yes in 2009, Korea has been the subject of a FATF Mutual Evaluation. Relevant report is available at the FATF Website (Link).
Questions
A8. The andthresholds
minimum Answers: for occasional transactions under which customer due diligence is not required are as follows:
- USD 5,000 or equivalent in the case of a transaction in a foreign currency; and

- KRW 10,000,000.
Transactions less than KRW 10,000,000 should be aggregated over a certain period. If the aggregated amount exceeds this threshold,
Country customer due diligence should be conducted.
by country comparison of high level Know Your Customer and Anti-Money Laundering information
Q9. What are the high

2009 PricewaterhouseCoopers. levelreserved.
All rights requirements for verification
PricewaterhouseCoopers of customer
refers identification
to the network of member firmsinformation
of

(individuals and legal entities)?
A9. Individual (including agent): Name, identification number, date of birth, nationality, address and contact (phone number, email address).
Profit organisation: Corporate name, registration number, category of business, address, contact and name of owner.
Non-profit organisation or others: Organisation name, registration number, category of business, address of headquarters and branches,
contacts and name of owner.
A11. If any suspicious fact about a beneficial owner is detected from a transaction, the regulations advise that the identity of the person and the
purpose of the transaction be obtained, although there is no detailed guidance on this. Identification and verification processes of
customers have been strengthened in the updated regulations and guidance, including verification of beneficial ownership.
A12. The revision to regulations in 2005 allows for some exceptions as follows:
a) cash payments and receipts between financial institutions;
b) cash payments and receipts with the central and provincial governments and public institutions; and
c) cash payments and receipts that are prescribed in the presidential decree because the transactions have no risk of money
laundering.
Simplified due diligence has been included in the updated regulations and guidance.
A13. The updated regulations recommend that enhanced customer due diligence is applied in respect of customers that fall into major high risk
categories specified by the FATF, such as Politically Exposed Persons (PEPs), private banking, correspondent banking and terrorist
facilitators/financiers.
A14. The updated regulations recommend that enhanced customer due diligence is applied to overseas PEPs.
A15. The updated regulations recommend that enhanced due diligence is performed for correspondent banking relationships.
A16. Yes.
Financial institutions must ensure that all electronic financial services and products, such as Automated Teller Machine (ATM) transactions,
A13. The updated regulations recommend that enhanced customer due diligence is applied in respect of customers that fall into major high risk
categories specified by the FATF, such as Politically Exposed Persons (PEPs), private banking, correspondent banking and terrorist
facilitators/financiers.

Know
Q14.
In what circumstances is additional due diligence required for Politically Exposed Persons (PEPs)?
Country
The updated regulations recommend that enhanced customer due diligence is applied to overseas PEPs.
A15. The updated regulations recommend that enhanced due diligence is performed for correspondent banking relationships.
A16. Yes.
A17.Financial institutions must ensure that all electronic financial services and products, such as Automated Teller Machine (ATM) transactions,

internet banking and telephone banking, are based on accounts established through face-to-face identification. Financial institutions must
also have policies and procedures in place to address any specific risks associated with non face-to-face transactions, and must implement
them when establishing new business relationships and conducting ongoing customer due diligence.
.
Reporting
Q18. To whom are Suspicious

2009 PricewaterhouseCoopers. Activity
All rights reserved. Reports (SARs) made?
PricewaterhouseCoopers Please
refers to the networkinclude
a link
of member firms to
of their website.

A18. Korea Financial Intelligence Unit (KoFIU) required Suspicious Activity Report (http://www.kofiu.go.kr).
A19. Volume of SARs

2011 329,463 SARs (KoFIU)

2011 USD1,116,247 million (Source: data.worldbank.org* )
A20. Yes financial institutions in Korea have obligations for Currency Transaction Reports (CTR), which is the requirement for reporting
transaction above KRW20,000,000 to KoFIU.
A21. Yes below KRW1,000,000 occasional transactions.
A22. Yes imprisonment for a period not exceeding 1 year or a fine not exceeding KRW5 million per individual responsible for SAR reporting.
A23. No.
A24. Yes on transaction monitoring progress, linked or individual transactions identified as suspicious should be reported to KoFIU.
No local AML regulations do not mention this issue, but transferring information of individual and financial transaction is prohibited by
A20. Yes financial institutions in Korea have obligations for Currency Transaction Reports (CTR), which is the requirement for reporting
A21. Yes belowabove
transaction KRW1,000,000 occasional
KRW20,000,000 transactions.
to KoFIU.
Know
Q21.
A21. by
Country
A22.
Yes below KRW1,000,000 occasional transactions.
Yescountry comparison
imprisonment of not
for a period high level Know
exceeding 1 year Your Customer
or a fine andKRW5
not exceeding Anti-Money
million perLaundering information
individual responsible for SAR reporting.
Q22.
Q23.
Are there any requirements (legal or regulatory) to use automated Suspicious Transaction monitoring technology?
A22.
A23.
Yes imprisonment for a period not exceeding 1 year or a fine not exceeding KRW5 million per individual responsible for SAR reporting.
No.
Q23.
Q24.
Are there any requirements (legal or regulatory) to use automated Suspicious Transaction monitoring technology?
Is there a requirement to obtain authority to proceed with a current/ongoing transaction that is identified as suspicious?
A23.
A24.
No.
Yes on transaction monitoring progress, linked or individual transactions identified as suspicious should be reported to KoFIU.
Q24.
Q25.
A24.
A25.
Yes on transaction monitoring progress, linked or individual transactions identified as suspicious should be reported to KoFIU.
No local AML regulations do not mention this issue, but transferring information of individual and financial transaction is prohibited by
Korean privacy regulations.
A25. No local AML regulations do not mention this issue, but transferring information of individual and financial transaction is prohibited by
Korean privacy regulations.
.
alternative
.
conversion factor is used.
All rights reserved. PricewaterhouseCoopers refers to the network of member firms of
International Limited, each of which is a separate and independent legal entity.
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Answers:
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Customer quick
quick reference
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guide
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level Know
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Your Customer
Customer and
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Philippines
Key contact: Jenny Arciga / Ma. Corazon Postal address: Last updated:
Echavez 29th Floor, Philamlife Tower, January 2013
Email: jenny.arciga@ph.pwc / 8767 Paseo de Roxas, Makati City 1226,
comma.corazon.echavez@ph.pwc.com Philippines
Tel: +63 (2) 845 2728 3012 3171
General
A1. Philippine Republic Act (R.A.) No. 9160 otherwise known as The Anti Money Laundering Act of 2001 (AMLA) was signed into law on 29
September 2001 and took effect on 17 October 2001. The Implementing Rules and Regulations took effect on 2 April 2002. On 7 March
2003, R.A. No. 9194 (An Act Amending R.A. No. 9160) was signed into law and took effect on 23 March 2003. The revised Implementing
Rules and Regulations took effect on 7 September 2003.
A2. N/A.
A3. The Anti Money Laundering Council (AMLC) of the Philippines - http://www.amlc.gov.ph/ .
A4. Anti Money Laundering Act (AMLA) at a Glance summary: http://www.amlc.gov.ph/amla.html

The Bangko Sentral ng Pilipinas (BSP; local central bank) issues Key Prudential Regulations on Money Laundering for bank and non-bank
financial institutions regulated by the BSP: http://www.bsp.gov.ph/regulations/key_aml.asp
A5. None. It should be noted that under R.A. 9160, only Covered Institutions are mandated by the AMLA to submit covered and suspicious
transaction reports to the AMLC. These are:
a) banks and all other entities, including their subsidiaries and affiliates, supervised and regulated by the BSP (or Philippine Central
Bank);
b) insurance companies and all other institutions supervised or regulated by the Insurance Commission; and
c) securities dealers, pre-need companies, foreign exchange corporations and other entities supervised or regulated by the
Philippine Securities and Exchange Commission.
Only Covered Institutions are required to establish and record the true identity of their clients based on official documents. They shall
maintain a system of verifying their legal existence and organisational structure, as well as the authority and identification of all persons
purporting to act on their behalf. Covered Institutions shall establish appropriate systems and methods based on internationally compliant
standards and adequate internal controls for verifying and recording the true and full identity of their customers.
A7. No.
exercise
of member
of another firms of
member

Know
Know Your
Your Customer quick reference
Customer quick reference guide
guide
Country
Country by
by country
country comparison of high
comparison of high level
levelKnow
KnowYour
Your Customer
Customerand
andAnti-Money
Launderinginformation
information
A8. None. The AMLA defines covered transactions as single transactions in cash or other equivalent monetary instruments involving a total
amount in excess of PHP500,000 within one banking day (equates to approx. GBP7,600). But regardless of whether these are covered
transactions, the establishment and recording of the true identity of clients of Covered Institutions would cover all their clients.
A9. Individuals: The following minimum information/documentation shall be obtained from individual customers: a) Name; b) Present address;
c) Permanent address; d) Date and place of birth; e) Nationality; f) Nature of work and name of employer or nature of self-
employment/business; g) Contact numbers; h) Tax identification number, Social Security System number or Government Services and
Insurance System number; i) Specimen signature; j) Source of funds; and k) Names of beneficiaries in cases of insurance contracts.
Corporate and Judicial Entities: The following minimum information/documentation shall be obtained from customers that are corporate or
judicial entities, including shell companies and corporations: a) Articles of Incorporation / Partnership; b) By-laws; c) Official address or
principal business address; d) List of directors / partners; e) List of principal stockholders owning at least 2% of the capital stock; f) Contact
numbers; g) Beneficial owners, if any; and h) Verification of the authority and identification of the person purporting to act on behalf of the
client.
A10. Individuals: Covered Institutions shall require customers to produce original documents of identity issued by an official authority, bearing a
photograph of the customer. Examples of such documents are identity cards and passports.
Corporate/Judicial Entities: Before establishing business relationships, Covered Institutions shall endeavour to ensure that the customer
is a corporate or judicial entity which has not been or is not in the process of being dissolved or wound up, or that its business or operations
have not been or are not in the process of being closed, shut down, phased out, or terminated.
Applicable to all types: No new accounts shall be opened and created without face-to-face contact and full compliance with the above
mentioned requirements.
Though it is not defined in the local regulations or guidance, as a common business practice, banks and other institutions require copies of
original documents to be certified as true copies by the issuing agency (e.g. copies of Articles of Incorporation / Partnership should be
certified by the Securities and Exchange Commission), or by an independent lawyer or public notary (in the case of certifications and
affidavits issued by an individual).
A11. When dealing with customers who are acting as trustee, nominee, agent or in any capacity for and on behalf of another, Covered Institutions
shall verify and record the true and full identity of the person(s) on whose behalf a transaction is being conducted.
Covered Institutions shall retain accounts only in the true and full name of the account owner or holder. The provisions of existing Philippine
laws regarding anonymous accounts, accounts under fictitious names, and all other similar accounts shall be prohibited.
.
Know Your
Know Your Customer
Customer quick quick reference
reference guide
guide
A15. Nothing specific mentioned in local regulations or guidance for due diligence procedures performed for correspondent banking relationships.
Nonetheless, when dealing with customers who are acting as trustee, nominee, agent or in any capacity for and on behalf of another,
Covered Institutions shall verify and record the true and full identity of the person(s) on whose behalf a transaction is being conducted.
A16. No however dealings with shell companies and corporations, being legal entities which have no business substance in their own right, but
through which financial transactions may be conducted, should be undertaken with extreme caution.
A17. No new bank accounts shall be opened and created without face-to-face contact and full compliance with the above mentioned
requirements.
In case a Covered Institution has doubts when dealing with customers who are acting as trustee, nominee, agent or in any capacity for and
on behalf of another, that they are being used as dummies in circumvention of existing laws, they shall immediately make the necessary
inquiries to verify the status of the business relationship between the parties.
Reporting
A18. AMLC: http://www.amlc.gov.ph/assistance.html
A20. Covered transactions are single transactions in cash or other equivalent monetary instrument involving a total amount in excess of
PHP500,000 within one banking day
Suspicious transactions are transactions with covered institutions, regardless of the amounts involved, where any of the following
circumstances exists:
a) there is no underlying legal/trade obligation, purpose or economic justification; the client is not properly identified;
b) the amount involved is not commensurate with the business or financial capacity of the client;
c) the transaction is structured to avoid being the subject of reporting requirements under the AMLA;
d) there is a deviation from the clients profile/past transactions;
e) the transaction is related to an unlawful activity/offense under the AMLA;
f) and transactions similar or analogous to the above.
A21. Refer to Q20 above.
.
c) the transaction is structured to avoid being the subject of reporting requirements under the AMLA;
d) there is a deviation from the clients profile/past transactions;
e) the transaction is related to an unlawful activity/offense under the AMLA;
f) and transactions similar or analogous to the above.

Know
Q21.
Questions Your
Answers:
Country
Refer to Q20 above.
. A22. Failure to keep records is committed by any responsible official or employee of a covered institution who fails to maintain and safely store
all records of all transactions of theinstitution, including closed accounts, for five years from the date of the transaction/closure of the
contained in thisaccount.
publicationPenalty is 6 months
without obtaining to 1 year advice.
specific professional imprisonment or aand
The application fine of not
impact lesscanthan
of laws vary PHP100,000
widely based on the butspecific
not more than PHP500,000,
facts involved. No representationor
orboth.
warranty (express
agents do not accept or assume any liability, responsibility or duty of care for any consequences of you or anyone else acting, or refraining to
Malicious reporting is committed by any person who, with malice or in bad faith, reports/files a completely unwarranted report or false act, in reliance on the information contained in this
information relative to money laundering transaction against any person. Penalty is 6 months to 4 years imprisonment and a fine of not less
than PHP100,000 but not more than PHP500,000, at the discretion of the court. The offender is not entitled to avail the benefits of the
Probation Law.

If the offender is a corporation, association, partnership or any judicial person, the penalty shall be imposed upon the responsible officers,
as the case may be, who participated in, or allowed by their gross negligence, the commission of the crime.
If the offender is a judicial person, the court may suspend or revoke its license.
If the offender is an unknown, he shall, in addition to the penalties prescribed, be deported without further proceedings after serving the
penalties prescribed.
If the offender is a public official or employee, he shall, in addition to the penalties prescribed, suffer perpetual or temporary absolute
disqualification from office, as the case may be.
Breach of confidentiality: When reporting covered or suspicious transactions to the AMLC, covered institutions and their officers/employees
are prohibited from communicating directly or indirectly, in any manner or by any means, to any person/entity/media, the fact that such
report was made, the contents thereof, or any other information in relation thereto. In case of violation thereof, the concerned official and
employee of the covered institution shall be criminally liable. Neither may such reporting be published or aired in any manner or form by the
mass media, electronic mail or other similar devices. In case of a breach of confidentiality published or reported by media, the responsible
reporter, writer, president, publisher, manager and editor-in-chief shall also be held criminally liable. Penalty is 3 to 8 years imprisonment
and a fine of not less than PHP500,000 but not more than PHP1 million.
A23. No, however, covered institutions are required to register with the AMLC and enrol in the online transactions reporting module and
covered/suspicious transaction reports module: http://www.amlc.gov.ph/archive.html#Registration
Detailed guidance can be found here: http://www.amlc.gov.ph/archive/Reporting%20Procedures.pdf
A24. Authority to Inquire into Bank Deposits: Notwithstanding the provisions of R.A. 1405 (Law on Secrecy of Bank Deposits), as amended, R.A.
No. 6426, as amended, R.A. No. 8791, and other laws, the AMLC may inquire into or examine any particular deposit or investment with any
banking institution or non-bank financial institution upon order of any competent court in cases of violation of this act when it has been
established that there is probable cause that the deposits/investments are involved/related to an unlawful activity as defined in Sec. 3(i) of
the AMLA or a money laundering offense under Sec. 4 thereof; except that no court order shall be required in cases involving kidnapping for
ransom; drug trafficking and related offenses; and hijacking, destructive arson and murder, including those perpetrated by terrorists against
non-combatant persons and similar targets.
A25. No.
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warranty act upon
contained vary
by law, representation or accept
does do not warrantyor(express
assume
or implied) is given as to the accuracy or completeness of the information contained in this publication, and, to the extent permitted by law, PricewaterhouseCoopers LLP, its members, employees
any liability, responsibility or duty of care for any consequences of you or anyone else acting, or refraining to act, in reliance on the information contained and
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Answers:
Know Your
Know Your Customer
Customer quick
quick reference
reference guide
guide
Country by
Country by country
country comparison
comparison of
of high
high level
levelKnow
KnowYour
Your Customer
Customerand
andAnti-Money
information
Pakistan
Key contact: Syed Faraz Anwer Postal address: Last updated:
Email: syed.faraz.anwer@pk.pwc.com State Life Building 1-C; I.I.Chundrigar Road January 2013
Tel: +92 21 32419828 Karachi
General
A1. The Anti Money Laundering (AML) Act was enacted in March 2010 after its approval by the Parliament of Pakistan. In addition, local
banking regulator SBP has issued detailed AML and CFT regulations, together with guidelines on risk based approach in 2012. The
following is the link to these guidelines: http://www.sbp.org.pk/bprd/2012/C2.htm
A2. Before issuance of the AML Act in 2010, the AML Ordinance was issued in 2007 by the President of Pakistan.
A3. State Bank of Pakistan is the regulator for AML controls for banking and related services while SECP (Securities and Exchange
Commission) is the regulator for all other entities. http://www.sbp.org.pk/ , http://www.secp.gov.pk/
A4. SBP has issued detailed guidelines on AML/CFT regulations, together with guidelines on risk based approach. The following is a link to
these guidelines: http://www.sbp.org.pk/bprd/2012/C2.htm
A5. Yes.
A6. Yes. SBP has issued detailed guidelines on AML/CFT regulations, together with guidelines on the risk based approach. The following is a
link to these guidelines: http://www.sbp.org.pk/bprd/2012/C2.htm. These contain detailed instructions on quantification of risk through a
defined risk matrix, specific risk profiling of customers, specific high risk elements and recommendations for EDD, general high-risk
scenarios/factors and general low risk scenarios/factors.
A7. Yes performed by Asia Pacific Group on Money Laundering Mutual Evaluation Report dated 9 July, 2009
http://www.apgml.org/documents/docs/17/Pakistan%20MER%20-%20final%20version.pdf
A8. No threshold defined in the AML Act 2010. However, organisations have defined their own internal monetary thresholds.
of any other refers to
member firm nor can it control thethe network
exercise
of of member
another firms of
member

scenarios/factors and general low risk scenarios/factors.
Know
Yes performed by Asia Pacific Group on Money Laundering Mutual Evaluation Report dated 9 July, 2009
http://www.apgml.org/documents/docs/17/Pakistan%20MER%20-%20final%20version.pdf

A8. No
Country by threshold
country defined in the AML
comparison Act 2010.
of high However,
level organisations
Know Your Customerhave and
defined their own internal
Anti-Money monetary thresholds.
Q9.
What areInternational
the high Limited, each of which is afor
level requirements separate and independent
verification legal entity.
of customer identification information

A9. As per SBP AML/CFT Regulations (para 3 of Regulation 1: Customer Due Diligence), for identity and due diligence purposes, at the
minimum, the following information shall also be obtained, verified and recorded on KYC/CDD form or account opening form:
a) Full name as per identity document;
b) CNIC/Passport/NICOP/POC/ARC number or where the customer is not a natural person, the registration/incorporation number or
business registration number (as applicable);
c) Existing residential address, registered or business address (as necessary), contact telephone number(s) and e-mail (as
applicable );
d) Date of birth, incorporation or registration (as applicable);
e) Nationality or place of birth, incorporation or registration (as applicable);
f) Nature of business, geographies involved and expected type of counter-parties (as applicable);
g) Purpose of account;
h) Type of account;
i) Source of earnings;
j) Expected monthly credit turnover (amount and no. of transactions); and
k) Normal or expected modes of transactions
In addition, there are defined documentation requirements to be fulfilled in relation to different categories of customers. For details please
refer to Annexure I of SBP AML/CFT Regulations pages 18-21: http://www.sbp.org.pk/bprd/2012/C2.htm .
A10. Banks/Development Finance Institutions (DFIs) shall ensure that the CNIC and the photograph are for the same person whose account is
being opened with them. The particulars/CNIC of such persons must be confirmed from the National Database Registration Authority
(NADRA) in writing or through its VeriSys system by the bank/DFI.
As per paragraph 4 of Regulation 1 of SBP AML/CFT regulations, the Bank/DFI shall verify identity documents of the customers from
relevant authorities/document issuing bodies and where necessary using other reliable, independent sources and retain on record copies of
all reference documents used for identification and verification. The verification shall be responsibility of concerned bank/DFI for which the
customer should neither be obligated nor the cost of such verification be passed on to the customers.
A11. As per paragraphs 7 and 8 of Regulation 1 of SBP AML/CFT regulations:
In case of beneficial owner(s) in relation to a customer, reasonable measures shall be taken to obtain information to identify and verify the
identities of the beneficial owner(s).
Where the customer is not a natural person, the bank/DFI shall (i) take reasonable measures to understand the ownership and control
structure of the customer for obtaining information required under Para 9 below and (ii) determine that the natural persons who ultimately
own or control the customer.
A12. Detailed guidelines are available in section F of SBP AML/CFT Guidelines on Risk Based Approach (paragraphs 7-9) on general low risk
scenarios/factors and their disposition.
A13. Section D of SBP AML/CFT Guidelines on Risk Based Approach (paragraph 4) provides specific high risk elements and recommendations
for EDD such as NPOs, NGOs, charities, associations, house wife accounts, landlords, proprietorships, self employed professionals,
landlords, on-line transactions, cash, wire transfers etc. These elements/factors are bifurcated into customers, products and services and
delivery channels with EDD measures specified against each of the above-mentioned elements/factors.
Paragraph 5 specifies general high-risk scenarios and factors, bifurcated into products, delivery channels and geographies or locations etc
with examples and the EDD measures to be employed.
Where the customer is not a natural person, the bank/DFI shall (i) take reasonable measures to understand the ownership and control
structure of the customer for obtaining information required under Para 9 below and (ii) determine that the natural persons who ultimately
own or control the customer.

Q12.In what circumstances are reduced/simplified due diligence arrangements available?
Know
A12.
Detailed guidelines are available in section F of SBP AML/CFT Guidelines on Risk Based Approach (paragraphs 7-9) on general low risk
scenarios/factors and their disposition.
A13. Section D of SBP AML/CFT Guidelines on Risk Based Approach (paragraph 4) provides specific high risk elements and recommendations
for EDD such as NPOs, NGOs, charities, associations, house wife accounts, landlords, proprietorships, self employed professionals,
landlords, on-line transactions, cash, wire transfers etc. These elements/factors are bifurcated into customers, products and services and
delivery channels with EDD measures specified against each of the above-mentioned elements/factors.
Paragraph 5 specifies general high-risk scenarios and factors, bifurcated into products, delivery channels and geographies or locations etc
with examples and the EDD measures to be employed.
.
A14. Paragraph 30 of Regulation 1 of the SBP AML/CFT regulations covers in detail the treatment for PEPs. In relation to PEPs and their close
2009 PricewaterhouseCoopers. All rights
associates or family reserved. PricewaterhouseCoopers
members, banks/DFIs shall: refers to the network of member firms of
a) implement appropriate internal policies, procedures and controls to determine if a customer or beneficial owner is a PEP;

b) obtain approval from the banks senior management to establish or continue business relations where the customer or a beneficial
owner is a PEP or subsequently becomes a PEP;
c) establish, by appropriate means, the sources of wealth or beneficial ownership of funds; including obtaining a self-declaration to
this effect; and
d) conduct during the course of business relations, enhanced monitoring of business relations with the customer.
A15. Regulations 2 of SBP AML/CFT regulations cover this topic in detail.
A16. Yes As per Regulation 2 of SBP AML/CFT regulations (paragraph 4),
No bank/DFI shall enter into or continue correspondent banking relations with a shell bank and shall take appropriate measures when
establishing correspondent banking relations, to satisfy them that their respondent banks do not permit their accounts to be used by shell
banks.
A17. In dealing with non face-to-face/online customers, adequate measures should be in place e.g. independent verification by a reliable third
party, client report from the previous bank/DFI of the customer etc.
Reporting
A18. For banking organisations, to the local regulator i.e. State Bank of Pakistan. http://www.sbp.org.pk/
A20. No.
A21. As per paragraph 7 of Regulation 4 of SBP AML/CFT regulations:

A18. For banking organisations, to the local regulator i.e. State Bank of Pakistan. http://www.sbp.org.pk/

Know
Q19.
What was the volume of SARs made to the authorities in the most recent year? Please state the GDP for the equivalent year.

A20. No.
Know
As per paragraph 7 of Regulation 4 of SBP AML/CFT regulations:
Banks/DFIs should note that STRs, including attempted transactions, should be reported regardless of the amount of the transactions; and,
Country by
the country comparison
CTRs should be reported of high
above thelevel Know
threshold Your Customer
of PKR2.5m and Anti-Money
as per requirements Laundering information
of AML Act.
.
Q22. Are
contained in this there any
publication penalties
without for nonprofessional
obtaining specific compliance with
advice. Thereporting requirements
application and impact of laws e.g. tipping
can vary widelyoff?
A22. No.
A23. Yes by SBP. The following are extracts from SBP AML/CFT Regulation No. 4 (paragraph 5):
Banks/DFIs are advised to make use of technology and upgrade their systems and procedures in accordance with the changing profile of
various risks. Accordingly, all banks/DFIs are advised to implement automated Transaction Monitoring Systems (TMS) capable of producing
meaningful alerts in real time, based on pre-defined parameters/thresholds and customer profile, for analysis and possible reporting of
suspicious transactions. Further, banks/DFIs shall establish criteria in their AML/CFT Policies for management of such alerts.
A24. No.
A25. No.
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Country by
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New Zealand
Key contact: Stephen Drain Postal address: Last updated:
Email: stephen.c.drain@nz.pwc.com Private Bag 92162, Auckland 1142, New January 2013
Tel: +64 9 355 8332 Zealand
General
A1. The current regime is captured under the Financial Transactions Reporting Act 1996. However, in October 2009 the Anti-Money Laundering
and Countering Financing of Terrorism Act 2009 was passed. Regulations to the Act were gazetted on 30 June 2011. Reporting entities
are required to be fully compliant within two years i.e. by 30 June 2013.
A2. N/A previous regime still in force until 30 June 2013.
A3. a) for banks, life insurers, and non-bank deposit takers, the Reserve Bank of New Zealand (Reserve Bank) is the relevant AML/CFT
supervisor: http://www.rbnz.govt.nz/
b) for issuers of securities, trustee companies, futures dealers, collective investment schemes, brokers, and financial advisers, the
Financial Markets Authority is the relevant AML/CFT supervisor: http://www.fma.govt.nz/
c) for casinos, non-deposit-taking lenders, money changers, and other reporting entities that are not covered by paragraph (a) or (b),
the Department of Internal Affairs is the relevant AML/CFT supervisor: http://www.dia.govt.nz/
A4. AML Programme guideline: http://www.rbnz.govt.nz/aml/4616911.pdf

Interpreting Ordinary course of business: http://www.rbnz.govt.nz/aml/4533970.pdf
Identity Verification Code of Practice: http://www.rbnz.govt.nz/aml/4512701.pdf
Auditing guideline: https://www.fma.govt.nz/media/1339626/guideline_for_audits_of_risk_assessments_and_aml_cft_programmes.pdf
A5. Under the current regime, there is no such requirement. Under the new Act, reporting entities will be required to re-verify existing customers
where there is both a material change in the nature or purpose of the business relationship and the reporting entity considers that it has
insufficient information on that customer.
For anonymous accounts, reporting entities with be required to undertake standard customer due diligence when they become aware of
existing anonymous accounts regardless of whether a material change in the nature or purpose of the business relationship has occurred.
A6. The current regime does not incorporate a risk based approach. However the new Act is risk based.
A7. Yes see following link: http://www.fatf-gafi.org/documents/documents/mutualevaluationofnewzealand.html

exercise
of member
of another firms of
member

A6. The current regime does not incorporate a risk based approach. However the new Act is risk based.
Questions
Know
Questions
A7.
Your
Answers:
Yes see following link: http://www.fatf-gafi.org/documents/documents/mutualevaluationofnewzealand.html

Customer
Country due comparison
by country diligence of high level Know Your Customer and Anti-Money Laundering information
Q8. Are there minimum All rights reserved. PricewaterhouseCoopers
transaction thresholds, under which refers tocustomer
the network due
of member
firms ofis
diligence not required?
A8. Yes under the current regime, occasional (cash) transactions under NZD10,000 will not require customer due diligence. Under the new
Act, Occasional Transactions thresholds have been established. These are thresholds at which customer due diligence will need
to be carried out in respect of occasional transactions including but not limited to:
a) those over NZD9,999.99;
b) cash transactions in a casino that are for NZD6,000 or more;
c) travellers cheques NZD5,000 ;
d) money & postal orders NZD1,000; and
e) foreign exchange transactions over NZD1,000.
A9. The current Financial Transactions Reporting Act (1996) requires that where a financial institution is required to verify the identity of a
customer and that verification must be carried out by means of documentary or other evidence that is reasonably capable of establishing the
identity of that person. However, the Act is silent on the exact documentation considered reasonably capable of proving a person's identity.
The proposed legislation will likely prescribe what identity information is required.
Requirements for verification of identity are explained in the following document : http://www.rbnz.govt.nz/aml/4512701.pdf
A10. Identification documents must be certified as a true copy by one of a number of categories of individuals. This largely remains unchanged
under the new regime.
A11. The beneficial ownership threshold level is to be set at 25%. This means any individuals owning 25% (or more) of a customer would be
subject to CDD requirements.
A12. Currently, the only exceptions to verification requirements are where a person has an account at two different institutions and wishes to
conduct a transaction from one account to the other. In this case, the first institution may rely on the fact that the second institution would
have verified the person's identity at the time that the facility was opened there. The only condition is that the first institution must satisfy
itself that the other facility exists. Also, when there are three or more facility holder's signatories to an account, only the principal facility
holder's identity has to be verified.
The new Act specifically deals with simplified CDD. The regulations also define the application of simplified due diligence in respect of
section 18(1) of the Act. Simplified due diligence is essentially reduced measures for entities that are deemed to be lower risk i.e.

Government departments, listed companies etc.
A13. The current Financial Transactions Reporting Act (1996) is relatively silent on enhanced customer due diligence.
Under the new Act, a reporting entity must conduct enhanced customer due diligence in accordance with sections 23 and 24 of the Act in
the following circumstances:
a) if the reporting entity establishes a business relationship with a customer that is
a. a trust or another vehicle for holding personal assets;
b. a non-resident customer from a country that has insufficient anti-money laundering and countering financing of terrorism
systems or measures in place; or
c. a company with nominee shareholders or shares in bearer form;
b) if a customer seeks to conduct an occasional transaction through the reporting entity and that customer is
c) if a customer seeks to conduct, through the reporting entity, a complex, unusually large transaction or unusual pattern of
transactions that have no apparent or visible economic or lawful purpose; or
d) when a reporting entity considers that the level of risk involved is such that enhanced due diligence should apply to a particular
.
situation.
b) if a customer seeks to conduct an occasional transaction through the reporting entity and that customer is
Questions and Answers: systems or measures in place; or

c) if a customer seeks to conduct, through the reporting entity, a complex, unusually large transaction or unusual pattern of
transactions that have no apparent or visible economic or lawful purpose; or
d) when a reporting entity considers that the level of risk involved is such that enhanced due diligence should apply to a particular
situation.
A14. The current Financial Transactions Reporting Act (1996) does not directly address PEPs. The new Act requires foreign PEPs to undergo
enhanced customer due diligence
A15. Under the new Act, the correspondent must:

a) gather enough information about the respondent to understand fully the nature of the respondents business; and
b) determine from publicly available information the reputation of the respondent and whether and to what extent the respondent is
supervised for AML/CFT purposes, including whether the respondent has been subject to a money laundering or financing of
terrorism investigation or regulatory action; and
c) assess the respondents anti-money laundering and countering financing of terrorism controls to ascertain that those controls are
adequate and effective; and
d) have approval from its senior management before establishing a new correspondent banking relationship; and
e) document the respective AML/CFT responsibilities of the correspondent and the respondent; and
f) be satisfied that, in respect of those of the respondents customers who have direct access to accounts of the correspondent, the
respondent:
a. has verified the identity of, and conducts ongoing monitoring in respect of, those customers; and
b. is able to provide to the correspondent, on request, the documents, data, or information obtained when conducting the
relevant customer due diligence and ongoing customer due diligence.
A16. Not under the current regime but is prohibited under the new Act.
A17. Under the current Financial Transactions Reporting Act (1996), the identity of those involved in non face-to-face transactions must be
verified.
Under the new regime, for non face-to-face transactions, identity documents can be endorsed by one of a number of nominated persons
(police officer, lawyer etc)
Reporting
Know
A18. Suspicious
Country Transaction Reports (STRs) are made to the New Zealand Polices Financial Intelligence Unit:
by country comparison of high level Know Your Customer and Anti-Money Laundering information
http://www.police.govt.nz/service/financial
.
Q19. What
contained in this was without
publication the volume ofspecific
obtaining SARsprofessional
made toadvice.
the authorities in and
The application theimpact
mostofrecent
laws canyear? Please
vary widely basedstate
on thethe GDP
specific forinvolved.
facts the equivalent year. or warranty (express
No representation
A19. Volume
publication or for of SARs:
any decision
2010 4,357 SARs
based on it.
2010 USD141,547 million (Source: data.worldbank.org*)
A20. No only a requirement for the reporting entity to file a STR if it has reasonable grounds to suspect that the transaction or proposed
transaction is or may be:
a) relevant to the investigation or prosecution of any person for a money laundering offence; or
b) relevant to the enforcement of the Misuse of Drugs Act 1975; or
c) relevant to the enforcement of the Terrorism Suppression Act 2002; or
d) relevant to the enforcement of the Proceeds of Crime Act 1991 or the Criminal Proceeds (Recovery) Act 2009; or
e) relevant to the investigation or prosecution of a serious offence within the meaning of section 243(1) of the Crimes Act 1961.
Q20.
A20.
Are there any obligations to report anything more than suspicious transactions e.g. unusual transactions, cash transactions above a certain
No only a requirement for the reporting entity to file a STR if it has reasonable grounds to suspect that the transaction or proposed
transaction is or may be:
a) relevant to the investigation or prosecution of any person for a money laundering offence; or
b)
only relevant to the for
enforcement of the Misuse
to fileofaDrugs
STR ifAct 1975; or
A20. transaction
No a requirement
c) relevant to the
is or may
the reporting entity it has
be: enforcement of the Terrorism Suppression Act 2002; or
reasonable grounds to suspect that the transaction or proposed

d)
a) relevant
relevant to
to the
the enforcement
investigation of
or the Proceedsofofany
prosecution Crime
personAct 1991 or the Criminal
for a money Proceeds
laundering offence;(Recovery)
or Act 2009; or

e)
b) relevant
relevant to
to the
the investigation
enforcement or of prosecution
the Misuse of of Drugs
a serious
Act offence
1975; orwithin the meaning of section 243(1) of the Crimes Act 1961.
c) relevant to the enforcement of the Terrorism Suppression Act 2002; or
d) relevant to the enforcement of the Proceeds of Crime Act 1991 or the Criminal Proceeds (Recovery) Act 2009; or
e) anyrelevant to the investigation or prosecution of a serious offence within the meaning ofLaundering
section 243(1)information
of the Crimes Act 1961.
Q21.Arecountry
Country by there de-minimis
comparison thresholds below
of high levelwhich
Knowtransactions
Your do not
Customer needand
to be reported?
Anti-Money
A21. No.
A21. No.
A22. It is an offence to fail to report a suspicious transaction, or to provide misleading information or unlawfully disclose a STR or fail to keep
Q22. Are there records
adequate any penalties for non
in relation compliance
to filing of STRswith reporting
or to obstructrequirements e.g. into
the investigation tipping off?
a STR.
Penalties are: to fail to report a suspicious transaction, or to provide misleading information or unlawfully disclose a STR or fail to keep
A22. It is an offence
a) in
adequate the case
records of an individual,
in relation to filing ofeither
STRsororboth of the following:
to obstruct the investigation into a STR.
a. a term of imprisonment of not more than 2 years:
Penalties are: b. a fine of up to NZD300,000; and
b)
a) inin the
the case
case ofof aanbody corporate,
individual, a fine
either of up
or both ofto NZD5
the million.
following:
a. a term of imprisonment of not more than 2 years:
b. a fine of up to NZD300,000; and
b) in the case of a body corporate, a fine of up to NZD5 million.
A23. No, but it is encouraged.

A23. No, but it is encouraged.

A24. No.
A24. No.
A25. No.
A25. No.
*
.* GDP at purchaser's prices is the sum of gross value added by all resident producers in the economy plus any product taxes and minus any subsidies not included in the value of the products. It is
This publication
calculated hasmaking
without been prepared
deductionsforfor
general guidance
depreciation of on mattersassets
fabricated of interest
or forfordepletion
the personal use of the reader,
and degradation and resources.
of natural does not constitute
Data are professional
in current U.S.advice. You
dollars. should
Dollar not act
figures forupon
GDP the
areinformation
converted from
domestic currencies without
using single obtaining
year specific professional
official exchange rates. For aadvice. The application
few countries where theand impact
official of laws can
exchange rate vary
doeswidely based
not reflect theonrate
the effectively
specific facts involved.
applied No representation
to actual or warranty
foreign exchange (express
transactions, an
or implied) is
alternative given as to
conversion the accuracy
factor is used. or completeness of the information contained in this publication, and, to the extent permitted by law, PricewaterhouseCoopers LLP, its members, employees and
agents
. do not accept or assume any liability, responsibility or duty of care for any consequences of you or anyone else acting, or refraining to act, in reliance on the information contained in this
publication or forhas
This publication anybeen
decision basedfor
prepared ongeneral
it. guidance on matters of interest for the personal use of the reader, and does not constitute professional advice. You should not act upon the information
contained
or implied)
in this publication without
is given as to the
Allobtaining
accuracy or
specificPricewaterhouseCoopers
rights reserved.
completeness
PricewaterhouseCoopers International Limited, each of which
professional advice. The application
of the is
information
a separatecontained
andnetwork
refers to the impact of
in this publication,
and independent
of member
laws canfirms
vary of

widely based on the specific facts involved. No representation or warranty (express
legal entity.
www.pwc.com.
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Answers:
Know Your
Know Your Customer
Customer quick
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guide
Country by
Country by country
country comparison
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of high
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levelKnow
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Your Customer
Customerand
andAnti-Money
information
Malaysia
Key contact: Alex Tan Postal address: Last updated:
Email: alex.tan@my.pwc.com Level 10, 1 Sentral, Jalan Travers January 2013
Tel: +60 3 2173 1338 Kuala Lumpur Sentral,
P O Box 10192,
50706 Kuala Lumpur, Malaysia
General
A1. 2002.
A2. N/A.
A3. Bank Negara Malaysia (the Central Bank).
A4. http://www.bnm.gov.my/guidelines/01_banking/03_anti_money/03_gl_amla_sectoral3.pdf
A5. No.
A6. Yes - a risk based approach is approved, but a specific approach is not detailed and it remains the responsibility of the reporting institution
to devise an approach.
A7. No
A8. No.
Q9.
2013 PwC. All What
rights are the Not
reserved. highforlevel
furtherrequirements for
distribution without theverification of customer
permission of PwC. identification
PwC refers to the network information
of member firms(individuals and legal entities)?
of PricewaterhouseCoopers International Limited (PwCIL), or, as the
to the
of of
network another
membermember

firms of
Know Your
Questions and Customer quick reference guide
Answers:
No.
Country
A9. Individuals: reporting

All rightsinstitutions should obtain at least: full
thename;
network date of birth; nationality; permanent and mailing address; and
NRIC/passport
PricewaterhouseCoopers number.
International
Institutions
Limited, each of which isshould verify
a separate
refers to
the identity,
and independent
of member
legalrepresentative
entity.
firms of

capacity, domicile, legal capacity, occupation or business
purpose of any person, as well as other identifying information on that person, whether an occasional or usual client, through the use of
documents such as an identity card, passport, birth certificate, driver's licence, or any other official or private document.
Corporates: reporting institutions should require the company/business to provide original documentation and copies should be made of
each of the following documents:
a) Memorandum and Articles of Association / Certificate of Incorporation / partnership;
b) identification documents of directors / shareholders / partners;
c) authorisation for any person to represent the company / business; and
d) identification document of the person authorised to represent the company / business in its dealing with the reporting institution.
A10. Original documents must be provided and the reporting institution should make copies, as required. Certified true copies / duly notarised
copies may be accepted.
A11. The reporting institution must identify and verify the beneficial owner. They should conduct customer due diligence on the natural person
that ultimately owns or controls the customer's transaction when they suspect the transaction is conducted on behalf of a beneficial owner
and not the customer who is conducting such a transaction. The customer due diligence conducted should be as stringent as that imposed
on an individual customer.
A12. A simplified customer due diligence process is adopted for lower risk categories of customers, business relationships or transactions. The
relevant simplified process may vary from case to case depending on the customers' background, transaction type and specific
circumstances.
A13. Local AML guidance requires an enhanced customer due diligence process for higher risk categories of customers, business relationships
or transactions. Enhanced due diligence should include at least obtaining more detailed information from the customer and through publicly
available information, in particular, on the purpose of the transaction and source of funds; and obtaining approval from the Senior
Management of the reporting institution before establishing the business relationship with the customer. Examples of higher risk customers
are individuals with high net worth, non-resident customers, individuals from locations known for their high rates of crime (e.g. drug
producing, trafficking, smuggling), countries or jurisdictions with inadequate AML/CFT laws and regulations as highlighted by the FATF,
PEPs, legal arrangements that are complex (e.g. trust, nominee), cash based businesses, and businesses/activities identified by the FATF
as of higher money laundering and financing of terrorism risk.
A14. PEPs are foreign individuals who have been or are being entrusted with prominent public functions, such as head of state or government,
senior politicians, senior government officials, judicial or military officials and senior executives of public organisations. Once a PEP is
identified, the reporting institution should take reasonable and appropriate measures to establish the source of wealth and funds of such a
person.

Know
There are no specific references to correspondent banking relationships in local AML guidance. However, if the correspondent banks are
located in countries or jurisdictions with inadequate AML/CFT laws and regulations as highlighted by the FATF, they are referred to as
higher risk customers and transactions. Hence, enhanced due diligence, as set out in A11 above, should be undertaken

.
A16.
This publicationThere areprepared
has been no specific references
for general guidance ontomatters
the prohibition
of interest forof
therelationships with
personal use of the shelland
reader, banks in constitute
does not local AML guidance.
professional advice. You should not act upon the information
Q17. In what circumstances

2009 PricewaterhouseCoopers. is additional
All rights reserved. due diligence required
PricewaterhouseCoopers for
refers to the non face-to-face
network of member firms transactions
of

and/or relationships?
Know
Q16.
There are no specific references to the prohibition of relationships with shell banks in local AML guidance.
Country
A17. Best practice requires that institutions pay special attention in establishing and conducting business relationships via information
communication technology, for example the internet, post, fax or telephone.
Reporting
A18. Financial Intelligence Unit, Bank Negara Malaysia

http://www.bnm.gov.my/index.php?ch=176&pg=490&ac=408
A20. All financial institutions must report all transactions over MYR50,000.
A21. No.
A22. Yes - MYR250,000 fine.
A23. No.
A24. No.
A25. No.
.
PwC of which
helps is a separate
organisations andand independent
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create theentity.

value theyre looking for. Were a network of firms in 158 countries with more than 180,000
www.pwc.com.
Knowand
Questions Your Customer
Answers: quick reference guide
Know
Know Your
Your
Country by country
Customer
comparisonCustomer
quick
quick
of high level Know Your Customer
reference
reference
and Anti-Money
guide
guide
Japan
Japan
Key contact: Mahito Shirai Postal address: Sumitomo Fudosan Shiodome Last updated:
Email: mahito.shirai@jp.pwc.com
Key contact: Mahito Shirai Hamarikyu Bldg,Sumitomo
Postal address: 8-21-1, Ginza, Chuo-ku,
Fudosan Shiodome January 2013
Last updated:
Tel: +81
Email: 3 3546-8450
mahito.shirai@jp.pwc.com Tokyo, 104-0061
Hamarikyu Japan Ginza, Chuo-ku,
Bldg, 8-21-1, January 2013
Tel: +81 3 3546-8450 Tokyo, 104-0061 Japan
General
General
A1. Based on the revisions of the FATF 40 Recommendations in 2003, Japan enforced the Act on Prevention of Transfer of Criminal Proceeds
in 2007.onThe
A1. Based theact has been
revisions amended
of the FATF 40onRecommendations
28 April 2011 and will be effective
in 2003, from 1 April
Japan enforced the2013. Several
Act on other of
Prevention laws implemented
Transfer for Anti-
of Criminal Proceeds
Money
in 2007.Laundering
The act hasmeasures includeon
been amended the28following:
April 2011 and will be effective from 1 April 2013. Several other laws implemented for Anti-
Moneya) Laundering
Anti-Drugmeasures
Special Prevention
include theLaw (1992);
following:
b)
a) Act on theSpecial
Anti-Drug Punishment of Organized
Prevention Crime (2000);
Law (1992);
b) Act on the Punishment of Organized Crime (2000);
A2. Under the Act on Prevention of Transfer of Criminal Proceeds (2008), the customer identification information for verification was as follows.
Natural person:
A2. Under the Act on name; address;
Prevention date ofof
of Transfer birth
Criminal Proceeds (2008), the customer identification information for verification was as follows.
Legal
Natural Entity:
person:name; location
name; of thedate
address; headof or main office
birth
Some of new name;
Legal Entity: CDD and AMLof
location program
the headrequirement will be implement from 1 April 2013. (Please see A9.)
or main office
Some of new CDD and AML program requirement will be implement from 1 April 2013. (Please see A9.)
etc.). Please include for
linkAML
to the regulator(s)
Q3. Who is the regulator controls for: (a)website
Banking; (b) Other financial Services; (c) Non financial sector (e.g. casinos, high value goods
A3. a) Japan Financial Services Agency (FSA): http://www.fsa.go.jp/en/index.html
b)
A3. a) There
Japan are respective
Financial regulatory
Services Agency agencies for each business operator:
(FSA): http://www.fsa.go.jp/en/index.html
http://www.npa.go.jp/sosikihanzai/jafic/jaficenglishpage/jaficenglish.html
b) There are respective regulatory agencies for each business operator:
http://www.npa.go.jp/sosikihanzai/jafic/jaficenglishpage/jaficenglish.html
local legislation? Please includeprovided
link to website,
Q4. Is there any practical guidance to firmswhere available.
by public authorities regarding AML requirements, beyond the FATF recommendations and
A4. Japan FSA has issued Comprehensive Supervisory Guidelines for the financial sector. Although they are general guidelines for financial
institutions, it contains
A4. Japan FSA has issued some guidance regarding
Comprehensive Anti-Money
Supervisory Laundering
Guidelines compliance.
for the financial http://www.fsa.go.jp/en/refer/legislation/index.html
sector. Although they are general guidelines for financial
institutions, it contains some guidance regarding Anti-Money Laundering compliance. http://www.fsa.go.jp/en/refer/legislation/index.html
A5. Financial institutions are required to verify the identity of customers upon undertaking the specified transactions from pre-existing
customers, where customer identification
A5. Financial institutions are required to verifywas not undertaken
the identity beforeupon
of customers the implementation
undertaking theof The Acttransactions
specified on Prevention of pre-existing
from Transfer of Criminal
Proceeds.
customers, where customer identification was not undertaken before the implementation of The Act on Prevention of Transfer of Criminal
Proceeds.

A6. Despite the fact that the AML regime in Japan is not risk based, some aspects of this approach are incorporated into the local guidelines
issued
A6. Despiteby the
the Japan
fact that FSA. According
the AML regime to
in local
Japanguidelines,
is not risk banks
based,are expected
some aspectsto of
establish and maintain
this approach an internalinto
are incorporated control environment
the local to
guidelines
detect,
issued bymonitor, and analyse
the Japan suspicious
FSA. According customers,
to local considering
guidelines, various
banks are factors
expected such as customer
to establish attributes,
and maintain transaction
an internal controltypes and customer
environment to
business profiles.
detect, monitor, and analyse suspicious customers, considering various factors such as customer attributes, transaction types and customer
In addition,
business the Japanese Bankers Association issued the Guidance Note on the Risk based Approach in November 2007 for combating
profiles.
money laundering and terrorist
In addition, the Japanese Bankersfinancing. The Guidance
Association issued theNote is available
Guidance Note for
on member
the Risk banks
based and advisesinon
Approach the implementation
November of the risk
2007 for combating
based
moneyapproach.
laundering and terrorist financing. The Guidance Note is available for member banks and advises on the implementation of the risk
based approach.
2013
2009 PwC.
context
All rights reserved. Not
PricewaterhouseCoopers. Allfor
requires, individualInternational
PricewaterhouseCoopers member firms
further
rights distribution
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firmsofofmember firms of PricewaterhouseCoopers International Limited (PwCIL), or, as the
entity and does not act as agent of PwCIL or any other member firm. PwCIL does not provide any services
to clients.
2009
responsible
PwCIL is not responsible All
PricewaterhouseCoopers. or liable
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of another member firms professional judgment or bind another member firm or PwCIL in any way.
legal entity.
Know
Know Your
YourCustomer reference guide
Country
Countryby
bycountry
country comparison
comparison of high level
of high level Know
Know Your
Your Customer
Customer and
and Anti-Money
information
A7. Japan was reviewed in October 2008- http://www.fatf-gafi.org/document/61/0,3746,en_32250379_32236963_41684733_1_1_1_1,00.html
A8. Yes - customer identification is not required for one-off cash transactions below JPY2,000,000 (approximately USD24,000) and one-off wire
transfer transactions below JPY100,000 (approximately USD1,200).
A9. The verification method of customer identification information varies depending upon customer types i.e., a natural person or legal entity:
Natural person:
The following information has to be verified from valid customer identification documents such as a driving licence, passport, alien
registration card or any other acceptable documents:
a) name;
b) address; and
c) date of birth.
In addition, the following information/ procedure will be required after 1 April 2013, based on the amended act:
d) occupation; and
e) purpose of the business relationship
f) verify that natural persons acting on behalf of account holder are so authorized.
g) For higher risk customer described in the ordinance, verify asset and/or income of the customer.
Legal Entity:
The following information has to be verified from valid identification documents such as certificate of registration, seal registration certificate
or any other acceptable documents:
a) name; and
b) location of the head or main office.
In addition, the following information/ procedure will be required after 1 April 2013, based on the amended act:
(a) business contents; and
(b) purpose of the business relationship.
(c) Identity of beneficial owner.
(d) verify that natural persons acting on behalf of the legal entity are so authorized.
(e) For higher risk customer described in the ordinance, verify asset and/or income of the customer.
A10. Upon receiving copies of identification documents, financial institutions are required to use registered mail (which cannot be forwarded) to
complete the customer identification process. The customer identification process is considered complete unless the registered mail is
returned to the financial institution as being undelivered.
A11. For legal entities, the beneficial owners owning more than 25% of its shares or voting rights are required to be identified and their identities
verified.
.
Questions
Knowand Answers:
Know Your
Country by country Customer
comparison of quick
high level Know Your Customer reference
and Anti-Money guide
A12. Reduced due diligence arrangements are not explicitly stipulated in law/regulations. Rather, the ordinance exempts certain types of
transactions from customer identification requirements (e.g. transactions with the government or governmental entities), due to no or limited
money laundering/terrorist financing risk.
A13. a) In cases where the Specified Operator suspects that the counterparty of the transaction may impersonate to be a customer or its
representative;
b) In cases where Specified Operator suspects that the counterparty of the transaction may be disguising identification items at the
execution of the transaction; or
c) Transactions with the Customer originating in Iran or North Korea.
When this is the case, Specified Operator must conduct CDD again. Additionally, when the transaction amount is above JPY2,000,000,
Specified Operator must verify asset and/or income of the customer.
A14. There is no legal obligation to undertake additional due diligence steps with respect to PEPs.
A15. There is a requirement in the ordinance that financial institutions to undertake enhanced due diligence steps with respect to correspondent
banking relationships. Additionally, local guidelines issued by the Japan FSA expect financial institutions to appropriately assess the
prospective foreign financial institutions before entering into the correspondent banking relationships.
A16. No - relationships with shell banks are not explicitly prohibited. However, local guidelines issued by the Japan FSA expect financial
institutions to ascertain that prospective foreign financial institutions are not shell banks.
A17. Upon initiating non face-to-face transactions such as internet or telephone banking, financial institutions are required to verify a customers
address by sending registered mail.
Reporting
Know
Country
A18. by country
SARs comparison
are submitted of highregulatory
to the respective level Know Your
agency Customer
(e.g., and Anti-Money
Financial Sector: Laundering
Japan FSA), and information
consolidated by JAFIC(Japan Financial
Intelligence Center).

2011 337,341 SARs
.
GDP
contained in this (in current
publication without prices):
obtaining specific professional advice. The application and impact of laws can vary widely based on the specific facts involved. No representation or warranty (express
*
2011astoUSD
or implied) is given 5,867,154
the accuracy million (Source:
or completeness data.worldbank.org
of the information )
contained in this publication, and, to the extent permitted by law, PricewaterhouseCoopers LLP, its members, employees and
A20. No.
Q19.
A19.
Q16.
Volume
Are of SARs: with shell banks specifically prohibited?
relationships
2011 337,341 SARs
Questions
GDP (in and
A16. Yes. Answers:
current prices):

2011 USD 5,867,154 million (Source: data.worldbank.org* )
Q17. This
In results
what in a ratio ofis1additional
circumstances SAR for every USD17.4required
due diligence million offorGDP.
non face-to-face transactions and/or relationships?
A17. Reporting entities are required to consider the additional risk posed by non face-to-face business, in accordance with the risk based
approach and procedures they have adopted. There are currently no specific rules or guidance relating to non face-to-face business.
Reporting
A20. No.
Q21.
A18.
Are there any
Suspicious de-minimis
Matter Reportsthresholds
are made below which transactions
to AUSTRAC, who act asdo not needand
Regulator to be
FIUreported?
http://www.austrac.gov.au/ .
A21. No.
A19.
Q22.
Volume of SARs:
2010/11 46,670 SARs (Referred to as SMR or SUSTRs in Australia vis a vis the AML/CTF Regulator (AUSTRAC))
A22. Yes, an
GDP (in administrative
current prices):penalty may be received from the respective authorities.
2010/11 USD1,379,382 million (Source: data.worldbank.org* )
Q20.
A23.
No.
A20. All Threshold Transactions (TTRs) over AUD10,000 in cash and all International Funds Transfer Instructions (IFTIs) are required to be
reported to AUSTRAC. In addition, Cross Border Currency movements must be reported to AUSTRAC, the Australian Customs Service or
the Police if over AUD10,000.
A24. No.
A21. No minimum threshold for suspicious activity (SMRs), or International Funds Transfers (IFTIs), but AUD10,000 for Cash Transactions
(TTRs).
A25. Yes.
*
.
* GDP at purchaser's
contained prices without
in this publication is the sum of gross
obtaining value professional
specific added by all advice.
residentThe
producers in theand
application economy
impact plus anycan
of laws product taxes and
vary widely minus
based anyspecific
on the subsidies notinvolved.
facts includedNo
in the value of theor
representation products.
warrantyIt (express
is
agents do not
calculated accept
without or assume
making any liability,
deductions responsibility
for depreciation or duty ofassets
of fabricated care for
or any consequences
for depletion of you or anyone
and degradation elseresources.
of natural acting, or Data
refraining
are intocurrent
act, in U.S.
reliance on the
dollars. information
Dollar contained
figures for GDP areinconverted
this from
domestic All rights
currencies using single year officialreserved.
exchangePricewaterhouseCoopers
rates. For a few countries refers
wheretothe
theofficial
network
of member
exchange rate firms
does of
not reflect the rate effectively applied to actual foreign exchange transactions, an
.
www.pwc.com.
Questions and
Answers:
Know Your
Know Your Customer
Customer quick
quick reference
reference guide
guide
Country by
Country by country
country comparison
comparison of
of high
high level
level Know
Know Your
Your Customer
Customer and
and Anti-Money
information
Indonesia
Key contact: Elizabeth Goodbody Postal address: Last updated:
Email: elizabeth.goodbody@au.pwc.com JI HR Rasuna Said Kav X-7 No. 6 Jakarta July 2009
Tel: +62 21 5212901 12940; Indonesia
Q1 In what year did the relevant AML laws and regulations become effective?
A1 2002 (amended 2003)
Q2 If the AML laws and/or regulations became effective in the last 2 years, what were the requirements of the previous AML regime?
A2 N/A
Q3 Is there a requirement to retrospectively verify the identity of customers before the date the new AML regime was introduced?
A3 No.
Q4 Is a risk based approach approved by the local regulator(s)?
A4 Yes - as required by the Bank of Indonesia (central bank) and the Ministry of Finance.
Q5 Has the country been the subject of a FATF (or FATF-style) Mutual Evaluation or IMF assessment exercise since 2003? If yes, please find a
link to a relevant report (if publicly available).
A5 No.
Q6 Are there minimum transaction thresholds, under which customer due diligence is not required?
A6 Yes - transactions amounting to IDR 100,000,000 for walk-in customers.
Q7 What are the high level requirements for verification of customer identification information (individuals and legal entities)?
A7 Financial institutions shall conduct a face-to-face meeting with prospective customers, at least once at the time of account opening.
Individuals: obtain name, address, date of birth and verification documentation from a regulatory body authorised to issue documents,
which includes customer's full name and photograph, and either address or date of birth, for example an identity card, passport or photocard
driving licence.
Corporates: obtain name, registration number, registration office in country of incorporation, tax registry number, business address, and
identity of personnel who have the legal authority to represent the company.
Q8 Where copies of identification documentation are provided, what are the requirements around independent verification or authentication?
A8 Original identification documents should be provided by the prospective customer, and the financial institution should have an adequate
record keeping system in relation to identification documents.
to the of another
network
member
of member

firms of
Know Your
Know YourCustomer
Customer quick
quick reference
reference guide
guide
Q9 What are the high level requirements around beneficial ownership (identification and verification)?
A9 The requirements for beneficial owners are the same as the requirements for individual and corporate customers.
Q10 In what circumstances are reduced/simplified due diligence arrangements available?
A10 Simplified due diligence arrangements are acceptable when other financial services firms are subject to the Money Laundering Regulations
or equivalent, and firms are regulated in Indonesia, or in a comparable jurisdiction by equivalent regulators.
Q11 In what circumstances are enhanced customer due diligence measures required?
A11 Banks should conduct enhanced due diligence where the customer:
a) originates from a high risk country or territory;
b) their business is categorised as high risk; or
c) is considered to be high risk due to his/her position as a high ranking public officer.
Q12 In what circumstances is additional due diligence required for Politically Exposed Persons (PEPs)?
A12 There is no clear definition of PEPs in AML Regulations. However, banks are required to perform enhanced due diligence for customers
who are high ranking public officials.
Q13 What enhanced due diligence must be performed for correspondent banking relationships (cross-border banking and similar relationships)?
A13 There are two conditions for compliant banking relationships:

a) if the correspondent bank is regulated by a territory which has the equivalent standard of KYC implementation to Indonesia, then a formal
letter should be written stating that the bank has implemented KYC in relation to the customer properly; and
b) if the correspondent bank is regulated by a territory which has lower KYC standards than Indonesia, then the bank shall conduct KYC
procedures with the customer.
Q14 Are relationships with shell banks specifically prohibited?
A14 Yes.
Q15 In what circumstances is additional due diligence required for non face-to-face transactions and/or relationships?
A15 Face-to-face meetings should be performed at least once in the account opening process. There is no other exception for this requirement.
.
PwC helps
This publication has been prepared for general guidance onorganisations and individuals
matters of interest create use
for the personal the value
of the theyre
reader,looking
and doesfor.not
Were a network
constitute of firms advice.
professional in 158 countries
You shouldwith more
not than 180,000
peopleprofessional
contained in this publication without obtaining specific who are committed to delivering
advice. The applicationquality in assurance,
and impact of laws tax
canand
varyadvisory services.
widely based Tellspecific
on the us whatfacts
matters to youNo
involved. and find out moreorby
representation visiting (express
warranty us at
www.pwc.com.
This publication ofbeen
has care for any consequences
prepared of you oron
for general guidance anyone else
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interestoronly,
refraining to act,
and does notinconstitute
reliance on the information
professional contained
advice. in this
You should not act upon
publication or for any decision based on it. the information contained in this publication without obtaining specific professional advice. No representation or warranty (express or implied) is given as
to the accuracy
PricewaterhouseCoopers International Limited, any
eachliability,
of which
or completeness of
responsibility
is a separateorand
the information
refers
dutyindependent
of care for any
contained
to the network
consequences
legal entity.
in this
of member publication,
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and, to the extent permitted by law, PwC does do not accept or assume
of you or anyone else acting, or refraining to act, in reliance on the information contained
Questions and
Answers:
Know Your
Know Your Customer
Customer quick
quick reference
reference guide
guide
Countryby
Country bycountry
country comparison
comparison of
of high
high level
level Know
Know Your
Your Customer
Customer and
and Anti-Money
information
India
Key contact: Nilaya Varma Postal address: Last updated:
Email: nilaya.varma@in.pwc.com PricewaterhouseCoopers Pvt. Ltd. January 2013
Tel: +91 (0) 124 4620562 / 540 8th Floor, Building 8, Tower B
DLF Cyber City, Gurgaon
Haryana-122002, India
General
A1. 2005.
A2. The Indian Prevention of Money Laundering Act was prepared in 2002. However, this act came into force in 2005 after the creation of the
Financial Intelligence Unit in India in November 2004.
A3. FIU (Financial Intelligence Unit) http://fiuindia.gov.in/
A4. RBI (Reserve bank of India) has issued guidelines on AML & KYC.
A5. No.
A6. Yes - the local regulator (Reserve Bank of India) allows banking companies, financial institutions and intermediaries to use a risk based
Approach.
A7. So far no, as India has recently become a full fledged member of FATF.
exercise
of member
member of

A6. Yes - the local regulator (Reserve Bank of India) allows banking companies, financial institutions and intermediaries to use a risk based
Approach.
Questions
Q7. Has and a linkAnswers:
the country been the subject of a FATF (of FATF-style) Mutual Evaluation or IMF assessment exercise in the last three years? If yes,
Know
A7.
So far no, as India has recently become a full fledged member of FATF.
Q8. IfbyYes, Are there minimum transaction thresholds, under which customer due diligence is not required?
Country country comparison
what are of high level
the various thresholds Know Your Customer and Anti-Money Laundering information
in place?
A8. There are requirements for banking companies, financial institutions and intermediaries to verify and maintain identification records of all
its clients. Banking companies, financial institutions and intermediaries have to maintain records in respect of:
a) all cash transactions of the value of more than rupees ten lakhs (Rupees One Million) or its equivalent in foreign currency;
b) all series of cash transactions integrally connected to each other which have been valued below rupees ten lakhs (Rupees One
Million) or its equivalent in foreign currency where such series of transactions have taken place within a month;
c) all cash transactions where forged or counterfeit currency notes or bank notes have been used as genuine or where any forgery
of avaluable security or document has taken place facilitating the transactions;
d) all suspicious transactions whether or not made in cash;
e) All customers who are classified as medium to high risk are subjected to DD checks but the KYC is mandatory for all clients as

per RBI guidelines
A9. The banking company, financial institution or intermediary must verify and maintain the records in respect of identity and current address of
the clients. The documents required are:
Individuals: Official valid documents such as passport, driving licence, Permanent Account Number (PAN) Card, Voter's Identity Card
issued by the Election Commission of India or any other document.
Corporate:
a) Certificate of incorporation;
b) Memorandum and Articles of Association;
c) a resolution from the Board of Directors and power of attorney granted to its managers, officers or employees to transact on its
behalf;
d) an official valid document in respect of managers, officers or employees holding an attorney to transact on its behalf.
Association of Persons or Body of Individuals:

a) resolution of the managing body of such association or body of individuals;
b) power of attorney granted to him to transact on its behalf;
c) an official valid document in respect of the person holding an attorney to transact on its behalf; and
d) such information as may be required by the banking company or the financial institution or the intermediary to collectively
establish the legal existence of such an association or body of individuals.
A10. Certified copies of an official valid document may be used.
A11. The banking company, financial institution or intermediary should take reasonable measures to identify the beneficial owner(s) and verify
his/her/their identity in a manner so that it is satisfied that it knows who the beneficial owner(s) is/are.
A12. Customers can be categorised based on their risk profile. For example, individuals and entities whose identities and sources of wealth can
be easily identified may be categorised as low risk. Reduced due diligence arrangements may be followed by the banking company,
financial institution or intermediary in the case of low risk customers.
.
A11. The banking company, financial institution or intermediary should take reasonable measures to identify the beneficial owner(s) and verify
his/her/their identity in a manner so that it is satisfied that it knows who the beneficial owner(s) is/are.

Know
Questions
A12. Your
Answers:
Customers can be categorised based on their risk profile. For example, individuals and entities whose identities and sources of wealth can
be easily identified may be categorised as low risk. Reduced due diligence arrangements may be followed by the banking company,

financial institution or intermediary in the case of low risk customers.
A13. Customers that are likely to pose a higher than average risk to the bank may be categorised as medium or high risk depending on
customer's background, nature and location of activity, country of origin, sources of funds and his client profile etc. Banks may apply
enhanced due diligence measures based on the risk assessment, thereby requiring intensive due diligence for higher risk customers,
especially those for whom the sources of funds are not clear. Examples of customers requiring higher due diligence may include
a) non-resident customers;
b) high net worth individuals;
c) trusts, charities, NGOs and organizations receiving donations;
d) companies having a close family shareholding or beneficial ownership;
e) firms with 'sleeping partners';
f) Politically Exposed Persons (PEPs) of foreign origin;
g) non-face to face customers; and
. h) those with a high risk reputation as per public information available etc.
Q14. In any
publication or for what circumstances
decision based on it. is additional due diligence required for Politically Exposed Persons (PEPs)?
A14.
International
Banks should gatherLimited, each of information
sufficient which is a separate and independent
on any legal entity.of this category
person/customer intending to establish a relationship and check all the

information available on the person in the public domain. Banks should verify the identity of the person and seek information about their
sources of funds before accepting the PEP as a customer. The decision to open an account for PEP should be taken at a senior level which
should be clearly identified in the Customer Acceptance policy. Banks should also subject such accounts to enhanced monitoring on an
ongoing basis. The above may also be applied to the accounts of the family members or close relatives of PEPs.
A15. Banks should gather sufficient information to understand fully the nature of the business of the correspondent/respondent bank. Banks
should try to ascertain from publicly available information whether the other bank has been subject to any money laundering or terrorist
financing investigation or regulatory action. It should also be satisfied that the respondent bank has verified the identity of the customers
having direct access to the accounts and is undertaking ongoing 'due diligence' on them. The correspondent bank should also ensure that
the respondent bank is able to provide the relevant customer identification data immediately on request.
A16. Guidance issued by the local regulator prohibits entering into a correspondent relationship with shell banks. Shell banks are not permitted to
operate in India. Banks should also guard against establishing relationships with respondent foreign financial institutions that permit their
accounts to be used by shell banks.
A17. In the case of non-face-to-face customers, apart from applying the usual customer identification procedures, the banks must adopt specific
and adequate procedures to mitigate the higher risk involved. If necessary, additional documents may be called for in such cases. In the
case of cross-border customers, there is the additional difficulty of matching the customer with the documentation and the bank may have
to rely on third party certification. In such cases, it must be ensured that the third party is a regulated and supervised entity and has
adequate KYC systems in place.
Reporting
A18. FIU: http://fiuindia.gov.in/

In India SAR are known as STR (Suspicious Transaction Reports).
.
2011 USD1,224.1 billion (Source: data.worldbank.org* )
Reporting

Q18.
Know
Questions
Q20.
A18.
Your
Answers:
FIU: http://fiuindia.gov.in/

In India SAR are known as STR (Suspicious Transaction Reports).
A20. Yes, As per the RBI & FIU guidelines, all banking institutions are required all such activities.
A19. As per report publically made available in 2008, only 1,916 Suspicious Transaction Reports (STRs) were filed last year thus placing India at
a low transactions
Cash 22nd position. IndiaRs
below contributes just not
50,000 need 0.022
be per cent of STRs filed globally.
reported.
A21.
2011 USD1,224.1 billion (Source: data.worldbank.org* )
.
Q22.
This Are
publication hasthere any penalties
been prepared for generalfor non compliance
guidance with reporting
on matters of interest requirements
for the personal e.g.and
use of the reader, tipping off?
does not constitute professional advice. You should not act upon the information
This resultswithout
in a obtaining
ratio of specific
1 SARprofessional
for everyadvice. The application
USD638.9 millionand
ofimpact
GDP.of laws can vary widely based on the specific facts involved. No representation or warranty (express
A22. There are punitive clauses in the existing PMLA -2002.
Q20. Are thereInternational
PricewaterhouseCoopers any obligations
threshold,
to report
Limited, each
international wire (legal
of whichanything
transfers,
more
is a separate than suspicious
and independent
other transactions etc.?
transactions e.g.
unusual transactions, cash transactions above a certain
legal entity.
Q23. Are there any requirements or regulatory) to use automated Suspicious Transaction monitoring technology?
A20. Yes, as
Yes, As per
per RBI
the RBI
and & FIU
FIU guidelines, all banking institutions are required all such activities.
guidelines.
A23.
Q21. Are
Is there
there any de-minimis
a requirement thresholds
to obtain below
authority to which transactions
proceed do not need to
with a current/ongoing be reported?
transaction that is identified as suspicious?
Q24.
A21. Cash transactions
Internal below
clearance is Rs 50,000 need not be reported.
required.
A24.
Q22. Are there

Does any penalties
the local legislationfor non transactions
allow compliance with
to bereporting
monitoredrequirements
outside the e.g. tipping off?
jurisdiction?
Q25.
A22. There are punitive clauses in the existing PMLA -2002.
Yes.
A25.
A23. Yes, as per RBI and FIU guidelines.
A24. Internal clearance is required.
A25. Yes.
**
.
* *
www.pwc.com.
warranty act upon
contained vary
warrantyor(express
assume
responsibility contained in thisfor
duty of care publication, and, to the
any consequences ofextent
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agents do not accept or assume any liability, responsibility or duty or
in this publication of for
care fordecision
any any consequences
based on it.of you or anyone else acting, or refraining to act, in reliance on the information contained in this
Questions and
Answers:
Know Your
Know YourCustomer
reference guide
guide
Countryby
Country bycountry
country comparison
comparison of
of high
high level
level Know
Know Your
Your Customer
Customer and
and Anti-Money
information
Hong Kong
Key contact: Rick Heathcote Postal address: Last updated:
Email: rick.heathcote@hk.pwc.com 21/F Edinburgh Tower; 15 Queen's Road January 2013
Tel: +852 2289 1155 Central; Hong Kong
General
A1. The primary legislation governing AML in Hong Kong is as follows:

a) Anti-Money Laundering and Counter-Terrorist Financing (Financial Institutions) Ordinance April 2012 (AMLO)
b) Drug Trafficking (Recovery of Proceeds) Ordinance - 1989 (amended 2005) (DTROP)
c) Organized and Serious Crimes Ordinance - 1994 (amended 2008) (OSCO)
d) United Nations (Anti-Terrorism) Measures Ordinance - 2002 (amended 2005) (UNATMO)
A2. The AMLO has become effective since April 2012. Previous AML regime was governed by DTROP, OSCO and UNATMO.
A3. The Financial Services and Treasury Bureau has taken over the overall co-ordinating role for anti-money laundering / counter-terrorist
financing policies and monitor Hong Kongs overall compliance with all the FATF
recommendations:(http://www.fstb.gov.hk/fsb/aboutus/welcome/index.htm)
The Hong Kong Monetary Authority (HKMA) is the regulator for AML controls for banking sector: (http://www.hkma.gov.hk/eng/index.shtml)
The Securities and Futures Commission (SFC) is the regulator for AML controls for securities
sector:(http://www.sfc.hk/sfc/html/EN/index.html)
The Officer of the Commissioner of Insurance (OCI) is the regulator for AML controls for insurance sector
(http://www.oci.gov.hk/about/index.html)
The Customs and Excise Department is the regulator for AML controls for money service operators (MSOs) (i.e. Remittance Agents and
Money Changers) (http://www.customs.gov.hk/en/home/index.html)
The Narcotics Division of Security Bureau (ND) will assist in overseeing the implementation of the FATF recommendations that are related
to the non-financial sectors and the non-profit organisations with a view to ensuring that the anti-money laundering / counter-terrorist
financing measures taken by the relevant sectors and organisations are in line with established international standards. It is responsible for
revising the guidelines for other non-financial sector (i.e. Designated Non-Financial Businesses and Profession (DNFBP) including
lawyers, accountants, estate agents, trust and company service providers, and precious metal and stone dealers).L
(http://www.nd.gov.hk/en/index.htm)
A4. Yes, the links of the guidance note issued by the relevant authorities are set out as below:
a) Guideline on Anti-Money Laundering and Counter-Terrorist Financing (For Authorized Institutions) issued by the HKMA (July
2012) (http://www.hkma.gov.hk/media/eng/doc/key-information/guidelines-and-circular/guideline/g33.pdf)
b) Guideline on Anti-Money Laundering and Counter-Terrorist Financing issued by the SFC (July 2012) (http://en-
rules.sfc.hk/net_file_store/new_rulebooks/h/k/HKSFC3527_3705_VER20.pdf)
c) Guideline on Anti-Money Laundering and Counter-Terrorist Financing (For authorized insurers, reinsurers, appointed insurance
agents and authorized insurance brokers carrying on or advising on long term business) issued by the OCI (July 2012)
(http://www.oci.gov.hk/download/appendixc.pdf)
d) Guideline on Anti-Money Laundering and Counter-Terrorist Financing (For Money Service Operators) issued by the Customs and
Excise Department (July 2012) (https://eservices.customs.gov.hk/MSOS/download/guideline/AMLO_Guideline_en.pdf)
e) Anti-Money Laundering & Counter-Terrorist Financing A Practical Guide for: Accountants, Estate Agents, Precious Metals and
Precious Stones Dealers and Trust and Company Service Providers (June 2009)
(http://www.nd.gov.hk/pdf/moneylaundering/AML_eng_full_version.pdf)
f) The Guideline for Precious Metals and Precious Stone Dealers (2008) (http://www.nd.gov.hk/pdf/pmpsd_guideline-e.pdf)
g) An Advisory Guideline on Preventing on Misuse of Charities for Terrorist Financing (July 2007)
(http://www.nd.gov.hk/pdf/guideline-e.pdf)
Q5.
2013 PwC. AllIsrights
there a requirement
reserved. Not for furthertodistribution
retrospectively
without theverify the of
permission identity
PwC. PwC of customers beforeofthe
refers to the network datefirms
member theofnew AML regime was
PricewaterhouseCoopers introduced?
International Limited (PwCIL), or, as the
exercise
of member
member of

c)
Guideline on Anti-Money Laundering and Counter-Terrorist Financing (For authorized insurers, reinsurers, appointed insurance
agents and authorized insurance brokers carrying on or advising on long term business) issued by the OCI (July 2012)
(http://www.oci.gov.hk/download/appendixc.pdf)
d) Guideline on Anti-Money Laundering and Counter-Terrorist Financing (For Money Service Operators) issued by the Customs and
Excise Department (July 2012) (https://eservices.customs.gov.hk/MSOS/download/guideline/AMLO_Guideline_en.pdf)
e) Anti-Money Laundering & Counter-Terrorist Financing A Practical Guide for: Accountants, Estate Agents, Precious Metals and
Precious Stones Dealers and Trust and Company Service Providers (June 2009)
Know Your
Questions and
f) Customer quick reference guide
(http://www.nd.gov.hk/pdf/moneylaundering/AML_eng_full_version.pdf)
Answers:
The Guideline for Precious Metals and Precious Stone Dealers (2008) (http://www.nd.gov.hk/pdf/pmpsd_guideline-e.pdf)

g) An Advisory Guideline on Preventing on Misuse of Charities for Terrorist Financing (July 2007)
(http://www.nd.gov.hk/pdf/guideline-e.pdf)
A5. No - although under

existing customers.
the
All rights revised
reserved.
As part
guidelines, enhanced
eachofoftheir
whichongoing AML
is a separate
refersAML
to the assessment
due diligence
and independent
requirements
network of member firms of are expected to be applied to all
process, intermediaries should consider and determine
legal entity.
customers, including

whether additional
identification information, in line with the current standards, should be obtained from all existing customers, particularly those customers in
higher risk categories. In particular, authorised institutions regulated by the HKMA are required to conduct a review at least on an annual
basis on all high risk customers to ensure that the customer's records maintained are up-to-date and relevant.
Under the AMLO, the identity of existing customers is not subject to retrospective verification. The AMLO only requires the financial
institution to review the documents, data and information relating to the customer that is held at the time it conducts the review.
A6. It is expected that financial institutions should adopt a risk based approach to customer due diligence and ongoing monitoring (e.g.
suspicious transaction monitoring).
A7. No.
A8. Generally speaking, the current legislation does not specifically set out minimum transaction thresholds where customer due diligence is or
is not required. However, less stringent due diligence requirements would be permitted in certain circumstances, such as:
a) a remittance / exchange transaction carried out by remittance agents / money changers, where the transaction amount is less
than HKD8,000 or equivalent; or
b) a transaction carried out by authorised institutions on behalf of a non-account holder, where the transaction amount is less than
HKD120,000 or equivalent.
A9. Individuals: The identity of an individual including his/her name, residential address (and permanent address if different), date of birth and
nationality, etc. should be obtained. Identification should be from documents issued by official or reputable sources, i.e., passports or
identity cards. The address should be checked by appropriate means, e.g. by reviewing utility or rates bills or checking the electoral roll.
Corporates: The following documents or information should be obtained, including the Certificate of Incorporation and Business
Registration Certificate, copy of the companys memorandum and articles of association, details of ownership and structure control of the
company, the board resolution evidencing the opening of the account and conferring authority on those who will operate it, identification
documents of the directors, principal shareholders and account signatories, as required. Additional requirements will arise for higher risk
customers.
A10. suitable certifier to certify that the copy document is a complete and an accurate copy of the original. Such certifiers include, inter alia, an
Copies of identification documentation should generally be checked against original documents. However, reliance may be placed on a
embassy, member of the judiciary, Justice of the Peace, etc.
A11. There is a requirement to identify the beneficial ownership and control, i.e. to determine which individual(s) ultimately own(s) or control(s)
the direct customer, and/or the person on whose behalf a transaction is being conducted. For corporates, the identity of the principal
shareholders (e.g. those holding 10% or more voting interests) should be identified. The identity of all shareholders holding 25% (for normal
risk circumstance) / 10% (for high risk circumstances) or more of the voting rights or share capital are required to be verified.
.
Q12. In what
or implied) is given as to circumstances are reduced/simplified
the accuracy or completeness due diligence
of the information contained arrangements
in this publication, and, to theavailable?
extent permitted by law, PricewaterhouseCoopers LLP, its members, employees and
A12. The HKMA, SFC and OCI all take a risk based approach and in the circumstances where there is no suspicion of money laundering, the
inherent International
risk of money laundering oristerrorist
PricewaterhouseCoopers Limited, each of which a separatefinancing is assessed
and independent legal entity.to be low, and
there is adequate public disclosure in relation to the
Questions
A11. There is and Answers:
a requirement to identify the beneficial ownership and control, i.e. to determine which individual(s) ultimately own(s) or control(s)

the direct customer, and/or the person on whose behalf a transaction is being conducted. For corporates, the identity of the principal
shareholders (e.g. those holding 10% or more voting interests) should be identified. The identity of all shareholders holding 25% (for normal
risk circumstance) / 10% (for high risk circumstances) or more of the voting rights or share capital are required to be verified.
A12. The HKMA, SFC and OCI all take a risk based approach and in the circumstances where there is no suspicion of money laundering, the
inherent risk of money laundering or terrorist financing is assessed to be low, and there is adequate public disclosure in relation to the
customers, a simplified due diligence arrangement may be adopted. Examples of customers who are of a lower risk are:
a) financial institutions authorised/supervised by the HKMA, SFC, OCI or by an equivalent authority in a jurisdiction that is a FATF
member or in an equivalent jurisdiction;
b) public companies that are subject to regulatory requirements, e.g. listing;
c) government or any public body (e.g. government department, legislative, municipal, etc.) in Hong Kong, or the government of an
equivalent jurisdiction or a body in an equivalent jurisdiction that performs functions similar to those of a public body;
d) companies which acquire an insurance policy for pension schemes which does not contain a surrender clause and the policy
cannot be used as collateral; and
e) companies which acquire a pension, superannuation or similar scheme that provides retirement benefits to employees, where
contributions are made by way of deduction from wages and the scheme rules do not permit the assignment of a members interest
under the scheme.
A13. Enhanced due diligence is required for higher risk categories of customers, business relationships or transactions. These may include
companies with unduly complex ownership structure, Politically Exposed Persons (PEPs), business relationships and transactions with
persons from or in jurisdictions that do not meet international AML standards, customers who are not physically present for identification
purposes, or remittance transactions for which the remittance messages do not contain complete originator information.
A14. Local regulatory guidance includes a requirement to gather sufficient information from a new customer and check publicly available
information to establish whether or not the customer is a PEP. The decision to open an account for a PEP should be taken at a senior
management level. A number of risk factors that institutions should consider in handling a business relationship with a PEP are also
outlined.
A15. A bank providing correspondent banking services is required to gather sufficient information about its respondent banks to understand their
business. Approval from senior management should be sought before establishing new correspondent banking relationships and the
respective responsibilities of each institution should be documented. A corresponding banking relationship should not be established unless
it is satisfied that the AML/CFT controls of the proposed respondent bank are adequate and effective. Particular care is required if a
correspondent banking relationship is maintained with banks incorporated in jurisdictions that do not meet international AML standards, or
where the respondent banks allow the direct use of the correspondent account by their customers to transact business on their own behalf
(i.e. payablethrough accounts).

Know
Yes.
A17. Firms are required to apply effective customer identification procedures to satisfy the true identity of the customer. Such procedures may
include:
a) requisition of additional documents to complement those required for face-to-face customers;
b) taking supplementary measures to verify all the information provided by the customer;
c) independent contact with the customer by the firm; and
d) requiring the first payment from the account to be made through an account in the customers name with a bank having satisfactory
customer due diligence standards.
.
Reporting
A18. SARs should be made to Joint Financial Intelligence Unit (JFIU) and the relevant regulator of the reporting entity.
Reporting
Questions
Know
SARs should be made to Joint Financial Intelligence Unit (JFIU) and the relevant regulator of the reporting entity.

2012 (up to August) 15,838 SARs.
A20. Financial institutions shall report to JFIU if there is knowledge or suspicion of ML/TF. Examples include, inter alia:
a) Customers are reluctant to provide normal information when opening an account, providing minimal or fictitious information or,
when applying to open an account, providing information that is complex or expensive for the institution to verify;
b) Customers who decline to provide information that in normal circumstances would make the customer eligible for credit or for other
banking services that would be regarded as valuable; etc.
A21. No.
A22. Yes.
A23. No
A24. have informed

Questions
Institutions are required to refrain from carrying out transactions which they know or suspect to be related to money laundering until they
and the
Answers:
JFIU which consents to the institution carrying out the transactions. Where it is impossible to refrain or if this is likely to
frustrate efforts to pursue the beneficiaries of a suspected money laundering operation, institutions may carry out the transactions and notify
JFIU on their own initiative and as soon as it is reasonable for them to do so.
.
A25. There are no explicit restrictions on offshore transactions monitoring provided that the other regulatory requirements are fulfilled.
www.pwc.com.
Questions and
Answers:
Know Your
Know Your Customer
Customer quick
quick reference
reference guide
guide
Country by
Country by country
country comparison
comparison of
of high
high level
level Know
Know Your
Your Customer
Customerand
andAnti-Money
information
China
Key contact: Jean Roux Postal address: 11/F PwC Center, 202 Hu Last updated:
Email: jean.roux@cn.pwc.com Bin Road, Shanghai 200021, P.R. China January 2013
Tel: +86 21 2323 3988
General
A1. The 2006/7 primary legislation governing AML in China is as follows:

a) Anti-money Laundering Law (2006)
b) Provisions on Anti-money Laundering through Financial Institutions (2006)
c) Administrative Measures for Financial Institutions on Report of Large-sum Transactions and Doubtful Transactions (2006)
d) Administrative Measures for Financial Institutions on Report of Transactions Suspected of Financing for Terrorist Purposes (2007)
e) Administrative Measures for Financial Institutions on Identification of Client Identity and Preservation of Client Identity Materials
and Transactions Records (2007).
A2. Prior to the Anti-Money Laundering Law, China issued three main regulations on monitoring and reporting large-sum and suspicious
transactions within financial institutions in 2003, requiring financial institutions to take the responsibilities for identifying, monitoring and
reporting of doubtful and suspicious capital flow.
Previously the regulations applied to proceeds of drug crime, organised crime, terrorism and smuggling. This has been broadened to
specifically include proceeds of corruption, taking bribes, violating the financial management order and financial fraud.
A3. The AML law in China covers both financial institutions which include banks, insurance companies, securities firms and other deposit taking
institutions, as well as the non-financial sector. The Peoples Bank of China (PBOC) is the main enforcement body who carry out on-site
inspections and apply fines if violations are found. The industry regulatory body for Banking is China Banking Regulatory Commission
(CBRC); for Insurance Firms and Securities firms it is respectively the China Insurance Regulatory Commission (CIRC) and China Securities
Regulatory Commission (CSRC). For Non-financial sectors, the general responsibility rests with the State Administration for Industry and
Commerce (SAIC).
A4. No.
A5. No.
A6. Yes - with the issuance of the latest KYC regulations in 2007, regulators require financial institutions to establish a risk-based KYC approach
and report to People's Bank of China (PBOC - Central Bank of China). Financial institutions should classify risk ratings according to the
characteristics of their clients and review the KYC documentation of higher risk clients every six months. The risk rating standards should be
reported to PBOC.
A7. FATF has completed an assessment of the implementation of anti-money laundering and counter-terrorist financing standards in the
2013 PwC. All People's Republic
rights reserved. Not for of China
further (China).
distribution The
without thefirst Mutual
permission Evaluation
of PwC. Report
PwC refers to the of China
network was adopted
of member by the FATF Plenary
firms of PricewaterhouseCoopers in JuneLimited
International 2007. (PwCIL), or, as the
exercise
of of member
another firms of
member

A5. No.

A6. Yes - with the issuance of the latest KYC regulations in 2007, regulators require financial institutions to establish a risk-based KYC approach
and report to People's Bank of China (PBOC - Central Bank of China). Financial institutions should classify risk ratings according to the
characteristics of their clients and review the KYC documentation of higher risk clients every six months. The risk rating standards should be
reported to PBOC.

Q7.
A7. by FATF has completed an assessment of the implementation of anti-money laundering and counter-terrorist financing standards in the
Country country
People's comparison
Republic of high
of China (China). level
The first Know Your Customer
Mutual Evaluation Report ofand Anti-Money
China Laundering
was adopted by information
the FATF Plenary in June 2007.
A8. Yes - for one-off services such as cash remittance, cash exchange and negotiable instrument cashing, the threshold is a one-off transaction
of RMB10,000 or foreign currency with a value of USD1,000 or equivalent. For property insurance contracts paid in cash, the threshold is a
single amount insurance premium of RMB10,000, or foreign currency of value USD1,000 or equivalent. For life insurance contracts paid in
cash, the threshold is a single amount insurance premium of RMB20,000 or foreign currency of value USD2,000 or equivalent. For any
insurance contracts paid by account transfer, the threshold is an insurance premium of RMB200,000 or foreign currency of value
USD20,000 or equivalent.
A9. If any financial institution establishes a business relationship with a client or provides one-off financial services such as cash remittance,
cash conversion and bill payment beyond the prescribed amount, it shall verify and record the customer name and identification number,
supported by original documentation. If the customer is represented by an agent, the financial institutions shall verify and record both the
agent and the principals identity details.
Individuals: financial institutions are required to verify the customer identification information by a site visit in a face-to-face meeting; they
should enquire with the public security bureau and check the online citizens identity information system owned by the PBOC.
Corporates: financial institutions are required to verify the customer identification information by a site visit in a face-to-face meeting; in
addition, they should enquire with the state administration of industry and commerce.
A10. Where copies of identification documentation are provided, financial institutions are required to confirm the certified copies with the
authentication body, to ensure the accuracy of the information provided. If the financial institution certifies the identity through a third party, it
should be assured that the third party has adopted measures for client identity clarification as prescribed by the present Law.
A11. If a financial institution establishes a business relationship of personal insurance or trust with its client, in the case that the contractual
beneficiary is not the client himself, the financial institution shall also verify and register the identity certificate or any other identification
document of the beneficiary.
A12. When one financial institution (the trustor) entrusts another financial institution (the trustee) to sell financial products to clients, the trustor
can rely on the customer due diligence conducted by the trustee based on the following conditions:
a) the customer due diligence undertaken by the trustee meets the requirements of anti-money laundering laws and regulations; and
b) the trustor is able to effectively obtain and preserve the KYC information.
.

Know
Questions
Q14. Your
Answers:
In what circumstances is additional due diligence required for Politically Exposed Persons (PEPs)?

None stated in local regulations or guidance.
Country
. A15. There is no specific regulation or guidance on this area in the 2007 AML law update . However, the Administration Regulation on Electronic
This publicationBanking
has been Business, published
prepared for general by on
guidance the China
matters Banking
of interest Regulatory
for the personal useCommission (CBRC),
of the reader, and covers professional
does not constitute electronicadvice.banking including
You should wire
not act upontransfer,
the information
internet banking and telephone banking. This requires that the financial institutions intending to provide cross-border electronic banking
services
agents do not accept mustany
or assume make anresponsibility
liability, application or to
dutythe CBRC
of care and
for any provide the
consequences following
of you or anyonedocuments:
else acting, or refraining to act, in reliance on the information contained in this
publication or for anya)decision
thebased
country
on it. and its law / regulation relating to electronic banking;
b) the main
PricewaterhouseCoopers the analysis
customers
All rights
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reserved. and
andeach
Limited, prediction
services it intends
of which isof the business
a separate
to to
refers provide;
the network of member firms of
volumelegal
and independent andentity.
the size of the customer
base in the next three years; and
d) the legal compliance analysis on cross-border electronic banking.
There is no other specific KYC or other requirement issued by the authorities that specifically covers correspondent banking.
A16. No.
Reporting
A18. China Anti-Money Laundering Monitoring and Analysis Center (CAMLMAC) http://www.camlmac.gov.cn/

2010 61.85 million SARs (Source: Peoples Bank of Chinas AML Report 2010)
GDP (in current prices)

2010 USD 6.7 trillion (Source: data.worldbank.org*)
This results in a ratio of 1 SAR for every USD108,326 of GDP.
A20. Different thresholds are used to define Large Value Transactions which are mandatory for reporting for individuals, the threshold is defined
as daily cash transaction over RMB200,000 or USD10,000; or wire transactions over RMB500,000 or USD100,000. For entities other than
individuals, the threshold is defined as RMB2 million or USD200,000.
A21. No.
*
.
Reporting
A20. Different thresholds are used to define Large Value Transactions which are mandatory for reporting for individuals, the threshold is defined
as daily cash transaction over RMB200,000 or USD10,000; or wire transactions over RMB500,000 or USD100,000. For entities other than
Q18. individuals, the threshold is defined as RMB2 million or USD200,000.

A18. China Anti-Money Laundering Monitoring and Analysis Center (CAMLMAC) http://www.camlmac.gov.cn/

A21. No. was the volume of SARs made to the authorities in the most recent year? Please state the GDP for the equivalent year.
What
Q19.
Country 2010
by country comparison
61.85 million of high
SARs (Source: level Know
Peoples Bank ofYour Customer
Chinas and
AML Report Anti-Money Laundering information
2010)
GDP (in current prices)
*
A22. 2010 USD
Yes, the Peoples
6.7 trillion (Source:
Republic of Chinas AML law states
data.worldbank.org ) that the Chairman, senior manager or any other person responsible are punishable.
Penalties include disciplinary sanction or revoking of qualification to hold a post, fine of RMB10,000 up to RMB500,000 to an individual
This
or/andresults in a ratioupofto1 RMB5
RMB20,000 SAR for everytoUSD108,326
million of GDP.
the organization. For very serious cases, the regulator can order to suspend business for
*
rectification
GDP at purchaser's or to
prices is the sumrevoke
of gross its business
value license.
added by all resident producers in the economy plus any product taxes and minus any subsidies not included in the value of the products. It is
Q20. Are there
alternative conversion any
factor obligations to report anything more than suspicious transactions e.g. unusual transactions, cash transactions above a certain
is used.
. threshold,
Are there international
any requirements wire transfers,
(legal other transactions etc.?
Q23.
This publication has been prepared for general guidance on or regulatory)
matters of interest to
for use automated
the personal Suspicious
use of the Transaction
reader, and does monitoring
not constitute professionaltechnology?
advice. You should not act upon the information
A23.
A20. Yes. orPBOC
agents do not Different
accept assume decree
thresholds 2 2006
are
any liability, usedrequires
to define
responsibility financial
or duty Large institutions
Value
of care for to monitor
Transactions
any consequences orand
which
of you report
are
anyone both large
mandatory
else acting, for value andinsuspicious
reporting
or refraining to act, on thetransactions
for individuals,
reliance based
the threshold
information contained ondefined
in is
this a set
of any
publication or as
for pre-defined
daily cashbased
decision patterns/threshold.
transaction
on it. over RMB200,000 or USD10,000; or wire transactions over RMB500,000 or USD100,000. For entities other than
individuals, the threshold
2009 PricewaterhouseCoopers. is defined
All rights reserved. as RMB2 million
PricewaterhouseCoopers or USD200,000.
refers to the network of member firms of
Q24. Is there
Are thereaany
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proceed with a current/ongoing
transactions do not need totransaction that is identified as suspicious?
be reported?
Q21.
A24. No.
No.
A21.
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Australia
Key contact: Steve Ingram Postal address: Last updated:
Email: steve.ingram@au.pwc.com Freshwater Place; Level 19; 2 Southbank January 2013
Tel: +61 3 8603 3676 Boulevard; Southbank; Victoria 3006
General
A1. 2006 (with staggered implementation from 13 December 2006 to 12 December 2008, thus phasing in the new legislation and replacing the
old). A second tranche to include accountants, lawyers, real estate and others has been delayed.
A2. There is no new legislation; however Rules are still being released. In addition, new sanctions legislation was enacted in 2011. The old
legislation (Financial Transaction Reports Act 1988) is still in force but applies to a limited number of entities.
A3. The Australian Transaction Reports and Analysis Centre (AUSTRAC) regulates AML across all industry sectors;
http://www.austrac.gov.au/
A4. Guidance on AML requirements has been provided by AUSTRAC:

http://www.austrac.gov.au/
A5. No - although there are certain 'trigger events' that require a reporting entity to verify the identity of existing customers. An example of such
a trigger event is the customer accessing a new product or service.
A6. Yes this is the central theme of the AML regime.
A7. No scheduled for 2013.
A8. No - however a certain number of exemptions have been provided for transaction thresholds in industries including bullion, low value
superannuation, gaming service providers and currency exchange at accommodation facilities.
exercise
of member
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A9. Individuals:
The reporting entity must obtain the customers name, residential address and date of birth. The customers full name and either their date
of birth or their residential address must be verified based on reliable and independent documentation and/or electronic data.
Corporates:
The reporting entity must collect from the customer the following information:
a) the company's full registered name;
b) registered address;
c) principal place of business address; and
d) Australian Company Number (ACN) or Australian Registered Business Number (ARBN).
This information can be verified using a range of documentation or electronic data. Reporting entities must include a procedure for the
reporting entity to verify, at a minimum, the following information about a company in the case of a domestic company:
a) the full name of the company as registered by the Australian Securities and Investments Commission (ASIC);
b) whether the company is registered by ASIC as a proprietary or public company; and
c) the Australian Company Number (ACN) issued to the company.
There is further guidance in chapter 4 of the AML/CTF Rules Instrument 2007 (No.1) where the customer is:
a) a domestic company;
b) a foreign company that has registered its presence in Australia; or
c) a foreign company that has not registered its presence in Australia.
There are also customer identification requirements for other types of entities such as trusts, associations and clubs, and due diligence
requirements for correspondent banking relationships.
A10. Identification documents must be certified as a true copy by one of a number of categories of qualified individuals including legal
practitioners, Justices of the Peace and Police Officers. A list of authorised persons can be found in chapter 1 of the AML/CTF Rules.
A11. A reporting entity must collect the full name and address of each beneficial owner of a public or proprietary company, other than a company
that is licensed and subject to the regulatory oversight of an Australian Commonwealth, State or Territory statutory regulator. The reporting
entity should take a risk based approach to determining whether and the extent to which this information should be verified. The reporting
entity should also take a risk based approach to determining whether to collect and/or verify the name and address of each beneficial owner
of a foreign public company, a domestic unlisted company, or a company that is licensed and subject to the regulatory oversight of a
Commonwealth statutory regulator. Australia is under pressure to expand the practical application of ultimate beneficial ownership, There
may therefore be changes in the future with respect to the level of beneficial ownership that is to be considered; currently at 25 % this is
being reconsidered in light of FATCA requirements and other changes from FATF that could bring the level to 10%.
A12. Simplified due diligence procedures are available to reporting entities in accordance with the risk based approach and procedures that they
adopt.
Certain pre-commencement customers are subject to modified identification procedures, in that those procedures do not have to be
completed prior to the commencement (or continuation, in this case) of the designated service. For information on medium or low risk
customers refer to chapter 4 of the AUSTRAC Regulatory
Guide available at www.austrac.gov.au .
A13. Enhanced due diligence procedures are required to be implemented by reporting entities in accordance with the risk based approach and
procedures that they adopt. Risk triggers specified in the rules as requiring enhanced customer due diligence are where the provision of a
designated service is high risk or when a suspicion has arisen. Also to be considered are prescribed foreign countries in relation to
prohibiting or regulating of transactions with them.
.
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A14. Reporting entities are required to consider the risk posed by PEPs in accordance with the risk based approach and procedures that have
been adopted by the reporting entity.
A15. Due diligence assessments must be carried out on the financial institution with which they wish to enter a correspondent banking
relationship, prior to the commencement of the relationship and at regular intervals thereafter.
A16. Yes.
approach and procedures they have adopted. There are currently no specific rules or guidance relating to non face-to-face business.
Reporting
A18. Suspicious Matter Reports are made to AUSTRAC, who act as Regulator and FIU http://www.austrac.gov.au/ .

2010/11 46,670 SARs (Referred to as SMR or SUSTRs in Australia vis a vis the AML/CTF Regulator (AUSTRAC))

reported to AUSTRAC. In addition, Cross Border Currency movements must be reported to AUSTRAC, the Australian Customs Service or
A21. No minimum threshold for suspicious activity (SMRs), or International Funds Transfers (IFTIs), but AUD10,000 for Cash Transactions
(TTRs).
*
.
Reporting
Questions
and Answers:
A18.
Suspicious Matter Reports are made to AUSTRAC, who act as Regulator and FIU http://www.austrac.gov.au/ .
Know
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Q22. Are thereany
2010/11 penalties
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(Referred with
to as SMR or reporting
SUSTRs requirements
in Australia vise.g. tipping
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the AML/CTF Regulator (AUSTRAC))
GDP (in currentunder

prices):
A22. Yes, prohibited criminal law and the AML/CTF Act 2006.

Q20.
A23. Are there any obligations
No requirement
threshold,
to report anything
to have automated more
monitoring, butthan
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Rules require e.g. unusual
each reporting transactions,
entity to cash transactions
have a suspicious above a certain
activity monitoring
program. international wire transfers, other transactions etc.?
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A24. No.
Q25.
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No minimum legislation
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or International jurisdiction?
Funds Transfers (IFTIs), but AUD10,000 for Cash Transactions
(TTRs).
A25. Yes, provided the requirements of the Privacy legislation and protocols are complied with. Rules silent on how to monitor and where
AUSTRAC focuses on appropriateness of arrangements.
*
.
.
www.pwc.com.
This publication
or implied) is given as to the accuracy or completeness has beencontained
in this guidance
publication, ontomatters
and, of interest
the extent only,
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PricewaterhouseCoopers International Limited, eachin thisofpublication or for anyand
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legal
United Kingdom
Key contact: Andrew P Clark Postal address: Last updated:
Email: andrew.p.clark@uk.pwc.com Hays Galleria, 1 Hays Lane, January 2013
Tel: +44 207 804 5761 London, SE1 2RD
General
A1. 1994 (amended 2003 and 2007). AML Regulations have taken effect in the UK since 15 December 2007. Changes to the Money
Laundering regulations 2007 came into force on 1 October 2012. The main changes relate to the fit and proper test (in relation to MSBs and
Trust and Company Service Providers), registration, the definition of a relevant person, penalties and disclosure.
A2. The changes to the Money Laundering regulations 2007 are to make the money laundering regime more effective and proportionate and
reduce the regulatory burden on British businesses.
A3. a)
b)
Financial Services Authority (FSA): http://www.fsa.gov.uk/
Financial Services Authority (FSA): http://www.fsa.gov.uk/
c) HM Revenue and Customs: http://www.hmrc.gov.uk/
The Law Society: http://www.lawsociety.org.uk/home.law
The Institute of Chartered Accountants in England and Wales (ICAEW): http://www.icaew.com
A4. Key sources of practical guidance with regard to AML requirements include:
a) Joint Money Laundering Steering Group (JMLSG): http://www.jmlsg.org.uk/
b) The Institute of Chartered Accountants in England and Wales (ICAEW): http://www.icaew.com/en/technical/legal-and-
regulatory/money-laundering/uk-law-and-guidance
c) HM Revenue and Customs: http://www.hmrc.gov.uk/MLR/
d) The Law Society: http://www.lawsociety.org.uk/productsandservices/practicenotes/aml.page
A5. No.
A6. Yes - with the Financial Services Authority leading the work in terms of firms legal obligations and their practical implementation.
A7. A mutual evaluation follow-up report was conducted in October 2009 and can be found at:http://www.fatf-
gafi.org/media/fatf/documents/reports/mer/FoR%20UK.pdf. This was a follow-up from the Mutual Evaluation conducted in June 2007 which
can be found at: http://www.fatf-gafi.org/media/fatf/documents/reports/mer/MER%20UK%20FULL.pdf
.
exercise of of
network
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member

firms of
A8. Yes - one off transactions below EUR15,000
A9. Evidence of identity can be in documentary or electronic form.
Individuals: full name, residential address and date of birth ideally from a government issued document which includes the customer's full
name and photo, and either residential address or date of birth e.g. valid passport, valid photo card driving licence etc;
or a government issued document (without a photograph) which includes the customer's full name, supported by a second document, either
a government-issued, or issued by a judicial authority, a public sector body or authority, a regulated utility company, or another FSA-
regulated firm in the UK financial services sector or in an equivalent jurisdiction, which includes the customer's full name and either
residential address or date of birth.
Corporates (other than regulated firms): full name, registration number, registered office in country of incorporation, business address.
Additionally, for private /unlisted companies: names of all directors (or equivalent), names of individuals who own or control over 25% of its
shares or voting rights and names of any individual(s) who otherwise exercise control over the management of the company.. The firm
should verify the existence of the corporate from either a confirmation of the company's listing on a regulated market or a search of the
relevant company registry or a copy of the company's Certificate of Incorporation. For private/unlisted companies, firms may decide,
following a risk assessment, to verify one or more of the directors as appropriate in line with CDD requirements for individuals. In respect of
Beneficial owners, the firm must take risk based and adequate measures to verify the identity of the Beneficial Owner(s).
A10. UK Guidance states that where identity is verified electronically, or copy documents are used, a firm should apply an additional verification
check to manage the risk of impersonation fraud. For example, one of these checks may be to require copy documents to be certified by an
appropriate person.
A11. The ML Regulations define beneficial owners as individuals either owning or controlling more than 25% of body corporates or partnerships
(or at least 25%of trusts) or otherwise owning or controlling the customer. These individuals must be identified, and risk-based and
adequate measures must be taken to verify their identities.
A12. Simplified due diligence may be applied to:

a) certain other regulated firms in the financial sector;
b) companies listed on a regulated market;
c) beneficial owners of pooled accounts held by notaries or independent legal professionals;
d) UK public authorities;
e) community institutions;
f) certain life assurance and e-Money products;
g) certain pension funds;
h) certain low risk products; and
i) child trust funds and junior ISAs.
A13. A firm must apply, on a risk-sensitive basis, enhanced customer due diligence measures and enhanced ongoing monitoring in any situation
which by its nature can present a higher risk of money laundering or terrorist financing. Three specific types of relationships where
enhanced due diligence measures must be applied are:
a) where the customer has not been physically present for identification purposes; or
b) in respect of a correspondent banking relationship with Respondents from non- European Economic Area ('EEA') states; or
.
c) in respect of a business relationship or an occasional transaction with a Politically Exposed Person ('PEP').
Q14. In what circumstances are additional due diligence required for Politically Exposed Persons (PEPs)?
A14. Firms are required, on a risk-sensitive basis, to:
a) have appropriate risk based procedures to determine whether a customer is a PEP;
b) obtain appropriate senior management approval for establishing the business relationship with that customer;
A13. A firm must apply, on a risk-sensitive basis, enhanced customer due diligence measures and enhanced ongoing monitoring in any situation
Questions
which byand Answers:
its nature can present a higher risk of money laundering or terrorist financing. Three specific types of relationships where
enhanced due diligence measures must be applied are:

a)
b)
c)
where the customer has not been physically present for identification purposes; or
in respect of a correspondent banking relationship with Respondents from non- European Economic Area ('EEA') states; or
in respect of a business relationship or an occasional transaction with a Politically Exposed Person ('PEP').
A14. Firms are required, on a risk-sensitive basis, to:

a) have appropriate risk based procedures to determine whether a customer is a PEP;
b) obtain appropriate senior management approval for establishing the business relationship with that customer;
c) take adequate measures to establish the source of wealth and source of funds which are involved in the proposed business
relationship or occasional transaction; and
d) conduct enhanced ongoing monitoring of the relationship.
A15. Best practice in the UK requires that due diligence should be undertaken using a risk-based approach.
Enhanced due diligence measures must be applied in respect of a correspondent banking relationship with Respondents from non-
European Economic Area ('EEA') states, but should be considered to be performed whenever the Respondent is considered to present a
greater money laundering/terrorist financing risk. The enhanced due diligence process should further consider the following
elements,designed to ensure that the Correspondent has secured a greater level of understanding of:
a) the Respondent's ownership and management;
b) the Respondent's business;
c) PEP involvement; and
d) the Respondent's AML / terrorist financing controls.
A16. Yes.
A17. Where a customer approaches firms by post, telephone or over the internet, i.e. has not been physically present for identification purposes,
the firms must take specific and adequate measures to compensate for this higher risk such as carrying out non face-to-face verification,
either electronically or by reference to documents.
UK Guidance states that where identity is verified electronically, or copy documents are used, a firm should apply an additional verification
check to manage the risk of impersonation fraud e.g. require copy documents to be certified by an appropriate person.
Reporting
A18. SOCA (Serious Organised Crime Agency): http://www.soca.gov.uk/

October 2011 to September 2012 278,665 SARs (Source: SOCA Annual report 2012)
.
A20. No. as to the accuracy or completeness of the information contained in this publication, and, to the extent permitted by law, PricewaterhouseCoopers LLP, its members, employees and
Q21. Are thereInternational Limited, each
any de-minimis of which isbelow
thresholds a separate and independent
which transactionslegal do
entity.
not need to be reported?

A21. No.
A22. Yes The Proceeds of Crime Act 2002 (POCA) outlines the following penalties with regard to reporting requirements:
a) Failure to report: up to five years imprisonment and/or an unlimited fine; and/or
b) Tipping off: up to two years imprisonment and/or unlimited fine
Changes to the Money Laundering regulations 2007 which came into force on 1 October 2012, include penalties imposed for failure to
A20. by
Country No.country comparison of high level Know Your Customer and Anti-Money Laundering information
A21. No.
A22. Yes The Proceeds of Crime Act 2002 (POCA) outlines the following penalties with regard to reporting requirements:
a) Failure to report: up to five years imprisonment and/or an unlimited fine; and/or
b) Tipping off: up to two years imprisonment and/or unlimited fine
Changes to the Money Laundering regulations 2007 which came into force on 1 October 2012, include penalties imposed for failure to
provide information required by notice.
A23. No, however, the transaction monitoring should be performed by using adequate means which assumes use of some automated
technology.
A24. Consent is required from SOCA (UKFIU) to proceed with a current/ongoing transaction that is identified as suspicious.
A25. No.
.
www.pwc.com.
Turkey
Key contact: Serkan Tarmur Postal address: Last updated:
Email: serkan.tarmur@tr.pwc.com Buyukdere Caddesi, Maya Akar Center, January 2013
Tel: +90 (212) 376 5322 K.8 34394 Esentepe, Istanbul
General
A1. The Law on Preventing Money Laundering (Law No: 4208) was enacted on 19 November 1996. This was subsequently updated and
strengthened by the Prevention of Laundering the Proceeds of Crime (Law No: 5549) which came into force on 18 October 2006 and was
amended on 1 April 2008, 07 July 2011, 26 September 2011, and 11 October 2011.
A2. N/A
A3. Financial Crimes Investigation Board (MASAK) http://www.masak.gov.tr/en/default.aspx , is the central authority for Suspicious
Transaction Reporting. Other regulators for the AML controls for (a) Banking; (b) Other financial Services; (c) Non financial sector are:
a) The Banking Regulation and Supervision Agency (BRSA) - http://www.bddk.org.tr/websitesi/English.aspx ;

b) The Capital Markets Board (CMB) - http://www.cmb.gov.tr/index.aspx ;
c) The Undersecretariat of Treasury - http://www.treasury.gov.tr/ .
A4. Yes - Financial Crimes Investigation Board (MASAK) has a series of guidance documents for firms subject to regulations.
http://www.masak.gov.tr/en/legislation/LaunderingProceedsofCrime/national-legislation.aspx
A5. No.
A6. Article 19 of the Regulation On Measures Regarding Prevention Of Laundering Proceeds Of Crime And Financing Of Terrorism says that
The obliged parties shall be required to follow up permanently the transactions conducted by their customers whether they are in
compliance with the information regarding the customers profession, commercial activities, business history, financial status, risk profile and
sources of funds within the scope of permanent business relationships and keep up-to-date information, documents and records regarding
the customer. Furthermore, the accuracy of information regarding the telephone and fax number and e-mail address of customers received
for customer identification shall be verified, if necessary, within the scope of risk-based approach using these means by contacting the
relevant person. Financial institutions shall also take the necessary measures in order to follow up the transactions conducted out of
permanent business relationship in the risk-based approach. Financial institutions shall establish, with this purpose, appropriate risk-
management systems.
Separately, the Ministry of Finance has the authority to determine obliged parties and specify the implementation of principles and
procedures, including measures to assign an officer with necessary authority at an administrative level for ensuring compliance with this
Law and to establish training, internal control and risk management systems regarding the size of business and business volumes.
.
2013 PwC.
accept reserved.
assume Not
consequences refers
context requires,
on it.
network
another firms of
member

A7. The latest FATF Mutual Evaluation Report is dated 2 April 2007 - http://www.fatf-
gafi.org/documents/documents/mutualevaluationofturkey.html
The latest IMF Financial System Stability Assessment is dated September 2012. http://www.imf.org/external/pubs/ft/scr/2012/cr12261.pdf .
A8. Yes. Obliged parties shall identify their customers or those who act on behalf or for the benefit of their customers by receiving their
identification information and verifying it:
a) Regardless of the monetary amount when establishing permanent business relationships. Customer identification shall be
completed before the business relationship is established or the transaction is conducted. When establishing permanent
business relationship, information on the purpose and intended nature of the business relationship shall be obtained.
b) When the amount of a single transaction or the total amount of multiple linked transactions is equal to or more than TRY20,000;
c) When the amount of a single transaction or the total amount of multiple linked transactions is equal to or more than TRY2,000 in
wire transfers;
d) Regardless of the monetary amount in cases requiring Suspicious Activity Report;
e) Regardless of the monetary amounts in cases where there is suspicion about the adequacy and the accuracy of previously
acquired identification information.
A9. Turkish national real persons: National identification card, driving licence or passport. In the case of a continuous transaction relationship:
any utility bill (water, electricity, gas etc.) issued within the last three months of the date of transaction for address verification.
Foreign national real persons: Passport, residence permit or other identification cards determined to be valid by the Ministry of Finance.
Address verification is the same as stated above.
Legal persons registered under Chambers of Commerce: Trade gazettes, national identification card, driving licence or passport for
Turkish national real persons and passport, residence permit or other identification cards determined by the Ministry of Finance for foreign
national real persons authorised to represent the company, signature circulars, list of authorised company representatives and their
signature circulars. The verification of the updated information is done through the Chamber of Commerce Databases and telephone, fax
and email verification through using the same channels.
Other detailed regulations exist for associations and foundations, unions and confederations, political parties, non-resident legal persons,
unincorporated organizations, public institutions, and those acting on behalf of others - see
http://www.masak.gov.tr/media/portals/masak2/files/en/Legislation/Regulations/measures.htm for details.
A10. Submitted national identification cards, passports, driving licences and residency permits should be originals or copies stamped by the
notary public. Trade gazettes and signature circulars should be stamped by Chambers of Commerce and public notaries, respectively.
A11. On behalf of real persons: National identification card, driving licence or passport of the person performing the transaction and the
beneficiary and proxy document stamped by the public notary.
Legal persons: Trade gazettes, signature circulars, list of authorised company representatives and their signature circulars of the
beneficiary, national identification card, driving licence or passport of the person performing the transaction. If the person performing the
transaction is not listed as an authorised company representative of the beneficiary, then a proxy document stamped by the public notary is
required.
.
Q12. In what circumstances are reduced/ simplified due diligence arrangements available?
A12. Financial institutions, bearing all responsibility, have the right to use third parties' (other financial institutions) identification of the customer
only if they are certain that the third party took all necessary measures and met the requirements of the regulation with respect to the
identification of the client and that the third party will provide identification documents stamped by the public notary at all times.
The Ministry of Finance facilitates customer due diligence for:

a) transfers between financial institutions realised on their own behalf;
b) situations where the client is a government body covered by Law No: 5018;
c) mass client acceptance within the framework of salary payment agreements;
d) private pension plans based on cut of salaries; and
e) listed companies.
A13. For complex and unusually high volume transactions, enhanced customer due diligence measures is required. There is a recommendation
by The Financial Crimes Investigation Board (MASAK) stating that banks should utilise enhanced due diligence procedures for high-risk
transactions. The risk is determined on the basis of various factors such as the background of the customer, country of residence, related
bank accounts and commercial activities.
A14. There is a recommendation by the Financial Crimes Investigation Board (MASAK) stating that financial institutions should utilise
appropriate risk management policies to determine whether the customer is a PEP. In addition, financial institutions should obtain senior
management approval to allow transactions for the PEP and to continue the relationship, if the beneficiary of an existing account turns out to
be a PEP. They are also required to take appropriate measures to determine the source of funds of PEPs and apply continuous monitoring
of their relationships with PEPs.
A15. Financial institutions shall take necessary measures in foreign correspondent relationships in order to:
a) Obtain, by making use of publicly available resources, reliable information on whether the respondent financial institution has
been subject to a money laundering and terrorist financing investigation and been punished as well as information on its business
field, reputation and the adequacy of inspection on it;
b) Assess anti-money laundering and terrorist financing system of the respondent financial institution and to ascertain that the
system is appropriate and effective;
c) Obtain approval from a senior manager before establishing new correspondent relationships;
d) Clearly determine their and the respondent financial institutions responsibilities by a contract in a way that meets the obligations
in Chapter 3 of Regulation on Measures Regarding Prevention of Laundering Proceeds of Crime and Financing Terrorism;
e) In cases where the correspondent relationship includes the use of payable- through accounts, be satisfied that the correspondent
financial institution has taken adequate measures pursuant to principles in the Chapter 3 of the Regulation on Measures
Regarding Prevention of Laundering Proceeds of Crime and Financing Terrorism and will be able to provide the identification
information of the relevant customers when requested.
A16. Yes. Financial institutions are prohibited to have respondent institution relationships with shell banks or with banks which are not confirmed
not to be shell banks.
A17. Financial institutions are required to take appropriate and effective measures including paying special attention to operations such as
depositing, withdrawing and wire transfers which are carried out by using systems enabling the institutions to conduct non face-to-face
transactions, closely monitoring the transactions that are not consistent with financial profile or activities of the customer or do not have
connection with their activities, and establishing a limit to amounts and number of transactions.
.Reporting
agents do not To whom are Suspicious Activity Reports (SARs)
for anymade? Please include a link
else to theiror website.
Q18. accept or assume any liability, responsibility
or duty of care consequences of you or anyone acting, refraining to act, in reliance on the information contained in this
A18. Suspicious ActivityAll rights reserved.
Reports arePricewaterhouseCoopers
made to Financial Crimes refers to the network of member
Investigation
Boardfirms(MASAK)
of

- http://www.masak.gov.tr/en/default.aspx
Reporting
A18. Suspicious Activity Reports are made to Financial Crimes Investigation Board (MASAK) - http://www.masak.gov.tr/en/default.aspx
A20. a) The obliged parties shall report to Financial Crimes Investigation Board (MASAK) any transactions exceeding the amount
determined by the Ministry of Finance to which they are party or intermediaries. (For this purpose, transactions which are linked to
each other as to their natures shall be considered as a single transaction. Transactions carried out at weekends, on holidays and
during night shall be considered as the transaction of the first workday following the date when the transactions were carried out.)
b) Transaction types subject to periodically reporting, reporting procedure and periods, excluded obliged parties and other
implementation principles and procedures shall be determined by the Ministry of Finance. The Ministry is authorised to
determine, separately for each obliged party, the principles and procedures of filling the periodical reporting forms, submitting
them to Financial Crimes Investigation Board (MASAK) through all types of electronic means and communication forms and
using electronic signature in the reports. Application dates for electronic reporting shall be determined by the Ministry of Finance.
A21. No.
A22. Yes Financial Crimes Investigation Board (MASAK) states that:
According to Article 13 of Law No. 5549; The obliged parties violating any obligation shall be punished with administrative fine of TRY5,000
by the Presidency. If the obliged party is a bank, finance company, factoring company, money lender, financial leasing company, insurance
and reinsurance company, pension company, capital market institution or bureau de change, administrative fine shall be applied two-fold.
A23. There is no clear requirement to use automated monitoring technology. However, the Article 5 of Law 5549 states that
In the scope of necessary measures, the Ministry of Finance has the authority to determine obliged parties and implementation principles
and procedures, including measures to assign an officer with necessary authority at administrative level for ensuring compliance with this
Law and to establish training, internal control and risk management systems by regarding size of business and business volumes.
A24. No.
A25. Yes.
.
www.pwc.com.
Switzerland
Key contact: : Patrick Meyer Postal address: Last updated:
Email: patrick.k.meyer@ch.pwc.com Birchstrasse 160, CH-8050 Zurich, January 2013
Tel: +41 58 792 2554 Switzerland
General
A1. 1977 (amended at various stages between 1982 and 2011).
A2. N/A.
A3. a) Swiss Financial Market Supervisory Authority (FINMA): http://www.finma.ch/e/pages/default.aspx

b) FINMA http://www.finma.ch/e/pages/default.aspx or various self-regulatory organisations (SROs),see a member list on
http://www.finma.ch/e/beaufsichtigte/sro/Pages/default.aspx
c) See (b)
A4. For Banks, the Swiss Banking Association provides an Agreement on the Swiss banks code of conduct with regard to the exercise of due
diligence (CDB 08) including a commentary: http://www.swissbanking.ch/en/home/publikationen-link/shop.htm.
A5. No - customer identification is not required, however the financial intermediary must identify beneficial owners retrospectively.
A6. Yes.
A7. Yes - http://www.fatf-gafi.org/dataoecd/29/11/35670903.pdf and follow-up report - http://www.fatf-gafi.org/dataoecd/53/52/43959966.pdf.
.
to the of another
network
member
of

A6. Yes.
Questions
Q7. Has the and
country Answers:
been the subject of a FATF (or FATF-style) Mutual Evaluation or IMF assessment exercise in the last three years? If yes,
Know
A7.
Yes - http://www.fatf-gafi.org/dataoecd/29/11/35670903.pdf and follow-up report - http://www.fatf-gafi.org/dataoecd/53/52/43959966.pdf.
A8. Yes - due diligence obligations can be waived if the business relationship only involves assets of low value and there is no suspicion of
. money laundering or terrorist financing. The relevant thresholds are:
a) prepared
This publication has been for electronic
for generalpayments
guidance on for services
matters and
of interest for goods: CHF5,000
the personal per calendar
use of the reader, year
and does not and per
constitute client; advice. You should not act upon the information
professional
or implied) is given asb)
to thefor bilateral
accuracy credit cards
or completeness (including
of the information department
contained in thisstore cards):
publication, and, CHF5,000 per month
to the extent permitted by law,and per client; and LLP, its members, employees and
agents do not accept c) in the
or assume anycase
liability,ofresponsibility
financial leasing, CHF25,000
or duty of care per calendar
for any consequences year
of you or andelse
anyone per client.
acting, or refraining to act, in reliance on the information contained in this
What are the high level requirements for verification of customer identification information (individuals and legal entities)?

Q9.
A9. Individuals: For face-to-face contact, the bank verifies identity via an official identification document with a photograph (passport, identity
card, driving licence, etc.) and puts on record the individuals full name, date of birth, address and nationality. For non face-to-face contact,
the bank obtains a certified copy of an official identification document, as well as a confirmation of the domicile indicated, either through an
exchange of correspondence or by any other appropriate method.
Corporates: With a registered office in Switzerland the bank ascertains whether the firms name is published in the official Swiss
Commerce Gazette or listed on a public website for commercial register entries. Private directories/databases can also be used. Otherwise,
identity must be established with an extract from the Commercial Register. Identity is verified with an extract from the Commercial Register
or extracts from public websites for Commercial Register entries, or equivalent documents substantiating the existence of the legal entity or
company (such as a certificate of incorporation). In addition, the identity of the individuals establishing the business relationship must also
be checked and the bank must take note of and document the contracting partners' power of attorney arrangements. Further, the financial
intermediary must acknowledge the provisions regulating the power to bind the legal entity, and verify the identity of the persons who enter
into the business relationship on behalf of the legal entity.
A10. Independent authentication of copies of official identification documents may be provided by branches, representative offices and
subsidiaries of the bank, correspondent banks, other financial intermediaries recognised by the account opening bank as well as notaries
and public authorities who customarily issue such confirmations of authenticity. Additionally, authenticated copies are issued by Post Offices
and SBB (Swiss Railway) stations.
A11. All due diligence which can be reasonably expected under the circumstances must be exercised in establishing the identity of the beneficial
owner. If there is any doubt as to whether the contracting partner is himself the beneficial owner, the bank shall require by means of Form A,
a written declaration setting forth the identity of the beneficial owner.
A12. It is not necessary to formally verify the identity of a contracting partner when:
a) an account, securities account or passbook is opened in the name of a minor by an adult third party, provided that the assets
deposited at the outset do not exceed CHF25,000; however, the identity of the adult opening the account must be verified;
b) a rental surety account is opened for a rented property located in Switzerland; or
c) the legal entity is listed at a stock exchange.
A13. Local regulations and guidance discuss higher risk business relationships and state various criteria that may be relevant to identifying higher
risk businesses e.g. the domicile of the contracting party and beneficial owner, type of business, origin country of payment, volume of
incoming funds, the complexity of the structures, notably in case of use of domicile companies and the absence of personal contact with the
beneficial owner. Politically Exposed Persons and correspondent banking are specifically covered.
A14. Business relationships with PEPs are regarded as higher risk and local regulations/guidance requires that enquiries should be made to
ascertain whether the contracting partner/beneficial owner is a PEP. The means of investigation for such higher risk business includes:
obtaining information in written or oral form from the contracting partner or beneficial owner, visits to the places of business of the
contracting partner and beneficial owner, consultation of publicly accessible sources and databases, and information from trustworthy
individuals where necessary.
.
c) the legal entity is listed at a stock exchange.
Know
A13.
Local regulations and guidance discuss higher risk business relationships and state various criteria that may be relevant to identifying higher
risk businesses e.g. the domicile of the contracting party and beneficial owner, type of business, origin country of payment, volume of
incoming funds, the complexity of the structures, notably in case of use of domicile companies and the absence of personal contact with the
beneficial
Country by countryowner. Politically Exposed
comparison of highPersons and correspondent
level Know bankingand
Your Customer are specifically
Anti-Money covered.
A14. Business relationships with PEPs are regarded as higher risk and local regulations/guidance requires that enquiries should be made to
ascertain whether the contracting partner/beneficial owner is a PEP. The means of investigation for such higher risk business includes:
obtaining information in written or oral form from the contracting partner or beneficial owner, visits to the places of business of the
contracting partner and beneficial owner, consultation of publicly accessible sources and databases, and information from trustworthy
individuals where necessary.
.
A15. For cross-border
agents do not accept banking
or assume any liability, relationships
responsibility with
or duty of careforeign banks, theoffollowing
for any consequences dueelse
you or anyone diligence
acting, or procedures
refraining to act,are to be on
in reliance performed in addition
the information contained intothis
the
standard
publication or for clarifications
any decision based on it. for high risk relationships: ensuring that the foreign bank is prohibited from entering into business relationships with
shell banks, clarifying
All rights the AMLPricewaterhouseCoopers
and CFT controls implemented by the foreign bank
of and examining whether the foreign bank is subject to an
equivalent
PricewaterhouseCoopers regulation
International
reserved.
andeach
Limited, supervision
of which is ainseparate
refers to the network
the anti-money laundering
and independent
of member firms

legal entity.and counter financing of terrorism domain. Furthermore a risk-based
procedure has to be established concerning the processing of repeated wire transfer instructions which lack the required sender information.
A16. Yes.
A17. In the case of business relations entered into through correspondence or via the internet, banks must verify the identity of the contracting
partner by obtaining a certified copy of an official identification document as well as a confirmation of the domicile indicated, either through
an exchange of correspondence or by any other appropriate method. Identification based on an official identification document at delivery or
receipt of mail is also deemed as sufficient proof of identity, provided that personal delivery to the recipient is thus warranted. In addition,
beneficial ownership according to Form A must invariably be provided by individuals entering into a business relationship with a bank
through correspondence. For business relationships established by electronic means, the bank shall identify, mitigate and control the risk
associated with the use of new technologies. The lack of personal contact with the contracting party and the beneficial owner is considered
an element of increased risk, according to the domain of activity of the bank.
Reporting
A18. Money Laundering Report Office (MROS):http://www.fedpol.admin.ch/content/fedpol/en/home/themen/kriminalitaet/geldwaescherei.html

2011 1,625 SARs (MROS)

A20. No.
A21. No.
2011 by
partner USD659,308
obtaining amillion (Source:
certified copy ofdata.worldbank.org ) document as well as a confirmation of the domicile indicated, either through
an official identification
an exchange of correspondence or by any other appropriate method. Identification based on an official identification document at delivery or
This results
receipt in is
of mail a ratio of 1 SARas
also deemed forsufficient
every USD405.7 million of
proof of identity, GDP. that personal delivery to the recipient is thus warranted. In addition,
provided
beneficial ownership according to Form A must invariably be provided by individuals entering into a business relationship with a bank
through correspondence. For business relationships established by electronic means, the bank shall identify, mitigate and control the risk
Questions
Q20. and Answers:
Are there any
associated withobligations
the use of to report
new anything more
technologies. thanof
The lack suspicious
personal transactions e.g.contracting
contact with the unusual transactions, cash
party and the transactions
beneficial ownerabove a certain
is considered

an elementinternational
threshold, of increasedwirerisk,transfers,
accordingother
to thetransactions
domain of activity
etc.? of the bank.
No.
Country
Reporting
A21. No.
A18. Money Laundering Report Office (MROS):http://www.fedpol.admin.ch/content/fedpol/en/home/themen/kriminalitaet/geldwaescherei.html
Q22. What Are there any penalties for non compliance with reporting requirements e.g. tipping off?
Q19. was the volume of SARs made to the authorities in the most recent year? Please state the GDP for the equivalent year.
A22.withoutAnyone
* GDP at purchaser's who
prices fails
is the sumtoofcomply with
gross value thebyduty
added to report
all resident shallin be
producers liable toplus
the economy a fine of up taxes
any product to CHF500,000, or in the
and minus any subsidies notcase of in
included negligence, upproducts.
the value of the to It is
A19.
calculated Volume
makingofdeductions
CHF150,000. SARs: for depreciation of fabricated assets or for depletion and degradation of natural resources. Data are in current U.S. dollars. Dollar figures for GDP are converted from
2011 using
domestic currencies 1,625
singleSARs (MROS)
year official exchange rates. For a few countries where the official exchange rate does not reflect the rate effectively applied to actual foreign exchange transactions, an
.
GDP
This publication (in current
has been prepared prices):
for general guidance on matters of interest for the personal use of the reader, and does not constitute professional advice. You should not act upon the information
* and impact of laws can vary widely based on the specific facts involved. No representation or warranty (express
Q23. 2011
Are
contained in this USD659,308
there
publicationany
without million
requirements
obtaining (Source:
(legal
specific data.worldbank.org
or regulatory)
professional advice. Theto )
use automated
application Suspicious Transaction monitoring technology?
publication or This
for
The results
anyAML
decision in a ratio
based
Ordinance of 1 SARbanks,
on it.requires for every
fundUSD405.7
manager,million
investmentof GDP.
companies and its asset managers and security dealers to operate an IT-
A23. based system for
2009 PricewaterhouseCoopers. transaction
All rights reserved. monitoring.
threshold, international to
Is there a requirement wire transfers,
obtain other
authority to transactions
proceed withetc.?
a current/ongoing transaction that is identified as suspicious?
Q24.
A24. The financial intermediary must immediately freeze the assets connected with the report filed. It must continue to freeze the assets until it
No.
A20. receives an order from the competent prosecution authority but, at the most, for five working days from the time the report is filed.
A21. No.
A25. Transaction monitoring may be outsourced to persons outside Switzerland, provided that the respective information is still available in
Switzerland and provided that the results are subject to a plausibility check in Switzerland. However, the Swiss financial intermediary
remains responsible. Furthermore, the client needs to be informed in case of a transfer of client information outside Switzerland.
.
www.pwc.com.
.
Sweden
Key contact: Karin Henrikson Postal address: Last updated:
Email: karin.henrikson@se.pwc.com Torsgatan 21, SE-113 21 Stockholm, January 2013
Tel: +46 (0) 709 294 358 Sweden
General
A1. In 2009, the 2009:62 Money Laundering and Terrorist Financing (Prevention) Act became effective.
A2. N/A.
A3. For general information in English: http://www.fi.se/Folder-EN/Startpage/Regulations/Money-laundering-/

a) The Swedish Financial Supervisory Authority (Finansinspektionen), http://www.fi.se/Regler/Penningtvatt/
b) The Swedish Financial Supervisory Authority only governs companies within the financial sector. For other sectors, different
regulators are in charge:
a. Casinos and lotteries: The Gaming Board for Sweden (Lotteriinspektionen), www.lotteriinspektionen.se/en/
b. Realtors: The Swedish Board of Supervision of Estate Agents (Fastighetsmklarnmnden),
http://www.fastighetsmaklarnamnden.se/
c. Other: the County Administrative Boards of Stockholm (http://www.lansstyrelsen.se/stockholm/En/Pages/default.aspx) ,
Vstra Gtaland (http://www.lansstyrelsen.se/vastragotaland/En/Pages/default.aspx) and Skne
(http://www.lansstyrelsen.se/skane/En/Pages/default.aspx) (http://www.bolagsverket.se/om/oss/fler/penningtvatt)
A4. Yes - by the Swedish Bankers Association, http://www.penningtvatt.se/
A5. Yes - if motivated by the risk for money laundering or terrorist financing.
A6. Yes.
A7. IMF Financial Sector Stability Assessment in 2011 (http://www.imf.org/external/pubs/ft/scr/2011/cr11172.pdf) and (http://www.fatf-
gafi.org/media/fatf/documents/reports/mer/FoR%20Sweden.pdf)

.
2013 PwC.
accept reserved.
assumeNot
consequences refers
context requires,
on it.
network
exercise of member
of another firms of
member

A6.

Know
IMF Financial Sector Stability Assessment in 2011 (http://www.imf.org/external/pubs/ft/scr/2011/cr11172.pdf) and (http://www.fatf-
gafi.org/media/fatf/documents/reports/mer/FoR%20Sweden.pdf)

.
contained in thisAre
Q8. there without
publication minimum transaction
obtaining thresholds,
specific professional under
advice. which customer
The application and impact ofdue
lawsdiligence is not
can vary widely required?
If Yes,
or implied) is given as to what are the
the accuracy various thresholds
or completeness in place?
of the information contained in this publication, and, to the extent permitted by law, PricewaterhouseCoopers LLP, its members, employees and
A8. Yes - single orAll

2009 PricewaterhouseCoopers. linked transactions
rights reserved. under EUR15,000.
A9. Reliable and independent information sources must be used and controls signed off and documented independently whether the customer
is a legal or physical entity. For example, evidence of identity can be in documentary or electronic form. The following information is
required:
Individuals: approved identification documents with name and social security number. Remote customers can be identified with an
approved electronic identity card to verify name, social security number and address. Foreigners must be identified through a passport and
a copy must be kept.
Legal entities: official registration documents and the identity of representatives through approved identification documents.
A10. Third parties can be used or the financial institution can choose to perform these controls in-house. However, the financial institution always
has responsibility for identification procedures and ensuring compliance with laws and regulations.
A11. Beneficial owners who control more than 25% of shares in a company or have significant influence over a company should be identified
directly through an identification check, through official databases or through other documents received that can verify the identity of the
beneficial owners.
A12. a) Swedish public authorities;

b) Firms within the European Union (EU) /European Economic Area (EEA) and specified countries that have similar AML/ CFT
legislation that conduct business as:
a. banks (as defined by Swedish law);
b. life insurance companies;
c. securities firms (as defined by Swedish law);
d. certain other financial firms that are registered with the Swedish Financial Services Agency (FSA) (as defined by Swedish
law);
e. insurance brokers (as defined by Swedish law);
f. firms that issue electronic money (as defined by Swedish law);
g. mutual funds (as defined by Swedish law); and
h. registered payment service providers and payment institutions (as defined by Swedish law).
c) Firms whose shares are listed on an exchange within EU/EEA as defined by 2004/39/EU or listed on an exchange outside the
EU/EEA where the requirements correspond to 2004/39/EU;
d) Life insurance products with an annual premium of maximum EUR1,000 or a one off premium of maximum EUR2,500;
e) Certain occupational pensions;
f) Electronic money with certain thresholds as defined by Swedish law;
g) Certain pooled accounts in EU/EEA or in territories outside EU/EEA provided that certain requirements are met.
A13. a) when a business relationship is established or an individual transaction is carried out with another at a distance.;
b) when establishing a business relationship or having a single transaction with a Politically Exposed Person (PEPs) who resides
abroad;
c) correspondent banking relationships with credit institutions outside EU/EEA; and
d) when the risk of money laundering or financing of terrorism is deemed to be high.
.
A14. a) the establishment of a business relationship; and

b) single transactions.
This only applies when the PEP is residing abroad.
A15. Gather sufficient information about the bank in order to assess the reputation of the bank and the quality of supervision, assess the banks
AML/CFT controls, document the controls of each institution, obtain internal approval to establish a correspondent banking relationship and
verify that the bank undertakes KYC procedures of its customers and can provide relevant information.
A16. Yes.
A17. When a business relationship is established or an individual transaction is carried out with another at a distance, such as opening bank
accounts online.
Reporting
A18. Financial Intelligence Unit (Finanspolisen), http://www.polisen.se/Om-polisen/Sa-arbetar-Polisen/Specialkompetenser/Finanspolisen/

2011 11,461 SARs (Financial Intelligence Unit - Finanspolisen)

2011 USD 538,131 million (Source: data.worldbank.org*)
A20. No.
A21. No.
.
2011 USD 538,131 million (Source: data.worldbank.org*)
Q17. In what
This circumstances
results in a ratio ofis1additional due diligence
SAR for every USD47.1required
million offorGDP.
non face-to-face transactions and/or relationships?
A17. When a business relationship is established or an individual transaction is carried out with another at a distance, such as opening bank
accounts online.
Q20.
Know
Reporting
No.
Country
A18. Financial Intelligence Unit (Finanspolisen), http://www.polisen.se/Om-polisen/Sa-arbetar-Polisen/Specialkompetenser/Finanspolisen/
A21. No.
Q22. Volume Are there any penalties for non compliance with reporting requirements e.g. tipping off?
A19.
* GDP
of SARs:
at purchaser's prices is the sum of gross value added by all resident producers in the economy plus any product taxes and minus any subsidies not included in the value of the products. It is
2011
calculated without 11,461
making SARs
deductions (Financial
for depreciation Intelligence
fabricated assetsUnit
or for- depletion
Finanspolisen)
Yes
A22.currencies
domestic
- non compliance which isofintentional or due and degradation of natural resources. Data are in current U.S. dollars. Dollar figures for GDP are converted from
to negligence carries penalties, according to Chapter 7 in 2009:62 Money Laundering and
using single year official exchange rates. For a few countries where the official exchange rate does not reflect the rate effectively applied to actual foreign exchange transactions, an
Terrorist Financing (Prevention) Act.
.
This publication2011 USD
has been 538,131
prepared million
for general (Source:
guidance data.worldbank.org*)
on matters of interest for the personal use of the reader, and does not constitute professional advice. You should not act upon the information
This results
Are there anyinany
a ratio
requirementsof 1 SAR fororor
(legal every USD47.1
regulatory) tomillion of GDP.
use automated of youSuspicious
or anyone elseTransaction monitoring technology?
Q23.
agents do not accept or assume liability, responsibility
duty of care for any consequences acting, or refraining to act, in reliance on the information contained in this
A23. No.
A20. No.
A24. No.
A21. No.
A25. No.
.
www.pwc.com.
.
Spain
Key contact: Francisco Velasco / Luis Postal address: Last updated:
Rodriguez Soler Edificio PricewaterhouseCoopers; Paseo January 2013
Email:francisco.velasco.correa@es.pwc.com de la Castellana; 259 B; 28046 Madrid;
/ luis.rodriguez.soler@es.pwc.com Spain
Tel: +34 91 568 4327 / +34 91 568 4107
General
A1. 2010 (pending approval of the new Royal Decree of Law 10/2010)
A2. Law 19/1993 regarding AML. (in force until 30 Mar 2010)
A3. SEPBLAC: (the Executive Service of the Commission for Monitoring Exchange Control Offences): www.sepblac.com
A4. SEPBLAC Reports and Publications

http://www.sepblac.es/espanol/informes_y_publicaciones/otra_documentacion.htm
A5. Untilthe issuing of the new Royal Decree for Law 10/2010, the following guidance under the previous regime are still applicable:
http://www.sepblac.es/espanol/legislacion/norma-blanqueo.htm
A6. Yes - SEPBLAC has been leading work to embed a risk based approach into AML controls, both in terms of firms' legal obligations and their
practical implementation. Law 10/2010 reinforces this approach by enlarging the range of industries and activities affected by the updated
regulation.
A7. Last Mutual Report FATF/GAFI (2006) : http://www.fatf-gafi.org/document/54/0,3746,en_32250379_32236963_37068662_1_1_1_1,00.html
A8. Yes - one-off transactions (single or linked) under EUR3,000.

.
Q9. What
or implied) is given as are
to thethe high orlevel
accuracy requirements
completeness for verification
of the information contained of customer
in this identification
publication, and, to the extentinformation (individuals
permitted by law, and legal entities)?
PricewaterhouseCoopers LLP, its members, employees and
2013 PwC.
accept reserved.
assume Not
consequences refers
you to
or the network
context requires, individual member firms
publication or for any decision based on it. of the PwC network. Each member firm is a separate legal entity and does not act as agent of PwCIL or any other member firm. PwCIL does not provide any services
to clients. PwCIL is not responsible
Individuals: or liable
firms for theobtain
should acts or omissions
a national of any of its member
identity firms norpermission
document, can it control the exercise
offirms of their professional
impeachment sent byjudgment or bind of
the Ministry them in any way.
Justice, No member
passport or firm is
A9.
government issuedLimited,
of any other
document
refers the
exercise of member
of another member of

PricewaterhouseCoopers International each ofwhich
which isincludes
a separate the customer's
and independent fullentity.
legal name and photograph. Additionally, firms must verify identification
documents of all authorised persons of the account.
Corporates: firms should obtain the following: full name, regulation form and number, business address and professional activity.
Additionally, names and regulation documents of all Attorneys should be obtained.
A8. by Yes - one-off transactions (single or linked) under EUR3,000.
A9. Individuals: firms should obtain a national identity document, permission of impeachment sent by the Ministry of Justice, passport or
government issued document which includes the customer's full name and photograph. Additionally, firms must verify identification
documents of all authorised persons of the account.
Corporates: firms should obtain the following: full name, regulation form and number, business address and professional activity.
Additionally, names and regulation documents of all Attorneys should be obtained.
A10. Copies should be certified by an appropriate person, for example an employee of the commercial office.
A11. The law determines that firms may consider it appropriate to verify the identity of appropriate beneficial owners. Where a principal owner is
another corporate entity or trust, the firm should take measures to look behind that company or trust and establish the identities of its
beneficial owners or trustees. The firm will then judge which of the beneficial owners exercise effective control, and whose identities should
therefore be verified.
A12. Simplified due diligence could be applied to some concrete clients and products. Detailed requirements for this are detailed in Law 10/2010,
Section 2, Articles 9 and 10.
A13. The law determines that firms will require additional measures of identification for certain business transactions, including private banking,
correspondent banking, on-line and telephone banking and currency exchanges. Enhanced due diligence must be applied for some
particular clients and products. Detailed requirements for these activities are detailed in Law 10/2010, Section 3, Article 11: in general terms,
and Article 16: for products and transactions where anonymous activity is possible.
A14. Law 10/2010, Articles 14 and 15 detail the due diligence and monitoring requirements for PEPs.
A15. Firms should take into account the greater potential for money laundering in a correspondent business relationship. Firms must send an
AML questionnaire to their correspondent banks to verify that these banks have measures to control money laundering. Law 10/2010 Article
13 details the requirements for correspondent banking relationships.
A16. Law 10/2010 Article 13 details the requirements for correspondent banking relationships. In particular, point 2 states that financial entities
do not set up relations or correspondent with shell banks.
A17. Firms should take account of the greater potential for money laundering in non face-to-face situations. Where a customer approaches a firm
remotely (by post, telephone or over the internet), the firm should carry out non face-to-face verification, either electronically, or by reference
to identification documents. Requirements for non face-to-face transactions and/or relationships are detailed in Law 10/2010, Article 12.
.
Reporting

A18. SEPBLAC: (the Executive Service of the Commission for Monitoring Exchange Control Offences) www.sepblac.com
A17. Firms should take account of the greater potential for money laundering in non face-to-face situations. Where a customer approaches a firm
Country
A17. by country
Firms comparison
should take of high
account of the greaterlevel Know
potential Your Customer
for money laundering inand Anti-Money
non face-to-face Laundering
situations. Where ainformation
customer approaches a firm
Reporting
Reporting
A19. In Spain, until 2009, SARs were reported to authorities split into 2 ways, the General regime (Financial entities, Insurance related) and the
Special
What wasregime, (notaries,
the volume attorneys,
of SARs made toauditors, accountants,
the authorities in thetax & legal
most advisors,
recent casinos,
year? Please real
state theestate,
GDP forjewellery, art dealers,
the equivalent year.numismatic &
Q19. stamps, professional funds transportation)
A19. InVolume
Spain, of SARs:
until 2009, SARs were reported to authorities split into 2 ways, the General regime (Financial entities, Insurance related) and the
2009 regime,
Special 2,590, divided as follows:
(notaries, General
attorneys, regime:
auditors, 2,326 and
accountants, taxSpecial
& legalregime 2,264.
advisors, casinos, real estate, jewellery, art dealers, numismatic &
stamps, professional funds transportation)
2009 of
Volume USD1,464,089
SARs: million (Source: data.worldbank.org * )
2009 2,590, divided as follows: General regime: 2,326 and Special regime 2,264.
2009 USD1,464,089 million (Source: data.worldbank.org * )
A20. There are two different types of reporting in Spain: Systematic Reporting and Suspicious Transaction Report.
A20. There are two

Are there any different
de-minimistypes of reporting
thresholds in Spain:
below Systematic Reporting
which transactions andtoSuspicious
do not need Transaction Report.
be reported?
Q21.
A21. Article 17 of Law 10/2010 states that, the subject will review transactions or operations regardless of the amount.
A21. Article 17 of
Are there Law
any 10/2010for
penalties states that, the subject
non compliance will reviewrequirements
with reporting transactionse.g.
or operations
tipping off?regardless of the amount.
Q22.
A22. Penalties for non compliance with Law 10/2010 requirements are detailed on Chapter VIII, Articles 50, 51, 52, 53, 54 and 55, and Sanctions
arethere
Are detailed
anyfrom articlefor
penalties 56,non
57 compliance
and 58. with reporting requirements e.g. tipping off?
Q22.
A22. Penalties for non compliance with Law 10/2010 requirements are detailed on Chapter VIII, Articles 50, 51, 52, 53, 54 and 55, and Sanctions
are
Aredetailed from
there any article 56, 57
requirements and or
(legal 58.regulatory) to use automated Suspicious Transaction monitoring technology?
Q23.
A23. Spanish Law 10/2010 has widened the scope of industries and activities to be monitored. All entities which have a large number of daily
transactions
Are there any are requested (legal
requirements to useor
automated Suspicious
regulatory) Transaction
to use automated monitoring
Suspicious technology.
Transaction Article 17
monitoring of Law 10/20120 stated that accurate
technology?
Q23. automated systems must be set up but adapted to the specific industry and Money Laundering risk. For these reasons, it was mandatory for
industries such as finance, insurance and online gambling to have automated systems.
A23. Spanish Law 10/2010 has widened the scope of industries and activities to be monitored. All entities which have a large number of daily
transactions are requested to use automated Suspicious Transaction monitoring technology. Article 17 of Law 10/20120 stated that accurate
automated systems must be set up but adapted to the specific industry and Money Laundering risk. For these reasons, it was mandatory for
Q24. Is there asuch
industries requirement to obtain
as finance, authority
insurance to proceed
and online with atocurrent/ongoing
gambling have automatedtransaction
systems. that is identified as suspicious?
A24. Law 10/2010 Article 19 details the requirement for injunctive enforcement.
A24. Law 10/2010

Does Article
the local 19 details
legislation allowthe requirement
transactions to for
be injunctive
monitoredenforcement.
outside the jurisdiction?
Q25.
A25. Law 10/2010
* GDP at purchaser's prices is theArticle
sum of 31 grossstates the requirements
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. publication or for any decision based on it.
contained in this publication without All
orPricewaterhouseCoopers
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agents do not accept or assume any liability, responsibility duty of care for consequences or anyone else acting, refraining to act, reliance the information contained in this
www.pwc.com.
PricewaterhouseCoopers International Limited, each This publication
of which is ahas been prepared
separate for general
and independent guidance
legal
Slovakia
Key contact: Katerina Halasek- Postal address: PricewaterhouseCoopers Last updated:
Dosedelovaerov Slovensko, s.r.o. Nmestie 1. mja 18, January 2013
Email: katerina.halasek- Bratislava 815 32, Slovak Republic
dosedelova@cz.pwc.com
Tel: +420-251151293
General
A1. 1994 this has been amended several times, and was fully replaced in 2008 by the Act no 297/2008 Coll. , effective from 1 September
2008 and last amended in 2011 - http://www.minv.sk/swift_data/source/policia/finpol/297_2008en.pdf
A2. N/A.
A3. The key regulator for AML controls is: the Financial analytical department (FAU) of the Police under the Ministry of Interior of the Slovak
Republic - http://www.minv.sk/?financna-policia
Controls are further regulated by:

National Bank of Slovakia ( www.nbs.sk ) which is a supervisory authority of the financial market in the Slovak Republic as well as the
Ministry of Finance of the Slovak Republic - www.finance.gov.sk
Administrative authorities and the Ministry of Finance supervise lotteries and other similar games, and holders of licenses to operate betting
games.
A4. Yes Guidelines for submitting AML notifications issued by the FAU:
http://www.minv.sk/?financna-policia
AML Guidelines for financial sector issued by the National Bank of Slovakia.
http://www.nbs.sk/sk/dohlad-nad-financnym-trhom/prevencia-legalizacie-prijmov-z-trestnej-cinnosti-a-financovania-terorizmu/odporucania-a-
metodicke-usmernenia
A5. No.
A6. Yes - National bank issued a guidelines in this respect for the banking sector
http://www.nbs.sk/_img/Documents/_Dohlad/ORM/BankyAOcp/MU_4_2009_AML_SK.pdf
.
2013 PwC.
accept reserved.
assumeNot
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of another firms of
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A5. No.

Q6.
Know
A6.
Yes - National bank issued a guidelines in this respect for the banking sector
http://www.nbs.sk/_img/Documents/_Dohlad/ORM/BankyAOcp/MU_4_2009_AML_SK.pdf
.
A7.
This publicationYes
has -been
MONEYVAL assessment
prepared for general guidance onSeptember 2011-
matters of interest http://www.coe.int/t/dghl/monitoring/moneyval/Countries/Slovakia_en.asp
for the personal use of the reader, and does not constitute professional advice. You should not act upon. the information

A8. Yes - any single transaction below EUR 15,000 does not require any customer due diligence unless it is a:
a) suspicious transaction;
b) an agreement to enter into a business relationship;
c) an agreement to establish an account, to make a deposit into a deposit passbook or a deposit certificate, or to make any other
type of deposit;
d) an agreement to use a safety deposit box or an agreement on custody;
e) transaction with a Politically Exposed Person ('PEP'); and
f) as part of the business relationship.
Also in the case of life insurance, the customer due diligence is not required if insurance premium payable per year does not exceed EUR
1,000 or if payable in lump-sum does not exceed EUR 2,500 and in certain situations related to pension scheme agreements (no amount
set by law).
An ordinary transaction below EUR 2,000 does not need customer due diligence.
A9. The following information is required:
Individuals: Name, surname, birth identification number or date of birth, place of birth, gender, address and citizenship. These would
normally be verified by an identity card or passport.
Individuals who conduct business: In addition to the above, full name of the business, place of business and identification number needs
to be noted.
Legal entities: the full name, residency/seat, identification (or similar identification received from foreign offices) showing evidence of the
companys existence (i.e. certificate of incorporation, trade register statement or other). The same principles for 'Individuals' apply for the
identification of individuals in the companys statutory body. If the companys statutory body or the owner is another legal entity,
identification documentation must also be collected for that entity. The way of acting of the statutory representatives, acting on behalf of the
legal must be proven, e.g. visible from the certificate of incorporation, trade register statement or other similar document, or power of
attorney must be provided by the client.
A10. These should be certified by an appropriate person e.g. a notary, local authorities etc. Specific rules apply to credit and financial institutions,
where certain employees are authorized to verify these when opening account, concluding contract, etc
A11. The shareholders of a legal entity (with more than 25% holding and/or voting rights) must be ascertained up to the level of the ultimate
beneficiary of the transaction, if there are suspicions. Direct and indirect ownership identification requirements are the same as for the
relevant legal entity and/or individual.
.
A10. These should be certified by an appropriate person e.g. a notary, local authorities etc. Specific rules apply to credit and financial institutions,
where certain employees are authorized to verify these when opening account, concluding contract, etc
Questions
Q11. What areand Answers:
the high level requirements around beneficial ownership (identification and verification)?
Know
The shareholders of a legal entity (with more than 25% holding and/or voting rights) must be ascertained up to the level of the ultimate
beneficiary of the transaction, if there are suspicions. Direct and indirect ownership identification requirements are the same as for the
relevant legal entity and/or individual.
A12. Simplified due diligence is applicable in the following situations:

a) The client is a credit or financial institution within EU or EEA;
b) The client is a listed entity in EU or EEA;
c) The client is public authority (specific conditions detailed in the law);
d) The client is the state;
e) In case of a life insurance contract to be concluded if insurance premium payable per year does not exceed EUR 1,000 or if
.
payableforingeneral
This publication has been prepared lump-sum
guidance does not exceed
on matters of interestEUR
for the2,500;
personaland
use of the reader, and does not constitute professional advice. You should not act upon the information
f) inwithout
contained in this publication certain situations
obtaining specificrelated to pension
professional advice. Thescheme
applicationagreements, both
and impact of laws canmandatory andonvoluntary
vary widely based the specific (no
facts amount setrepresentation
involved. No by law). or warranty (express

2012 PricewaterhouseCoopers. are enhanced
All rights reserved. customer duerefers
PricewaterhouseCoopers diligence measures
to the network required?
of member
firms of

A13. Enhanced customer due diligence is applicable for:
a) a remote financial services agreement;
b) a transaction and business relationship with a Politically Exposed Person ('PEP'); and
c) a correspondent bank relationship with a foreign credit or similar institution ('Correspondent Institution').
A14. All transactions with PEPs are subject to due diligence including the provision of information and supporting documentation relating to:
a) the purpose and intended nature of the transactions or business relationship;
b) the beneficial owner, if the client is a legal entity;
c) the information required for continuous monitoring of the business relationship; and
d) a review of the income source.
A15. Prior to the creation of a correspondent banking relationship, the following is required:
a) sufficient information on the relevant correspondent institution and the nature of its operations;
b) publically sourced information to establish the quality of supervision overseeing the correspondent institution;
c) an evaluation of measures applied by the correspondent institution against the legitimisation of proceeds of crime and financing
terrorism;
d) understanding if approval of relevant lead employee to open the corresponding bank relationship was granted, and
e) in case of wire transfer, confirmation from the correspondent bank that it has identified the account holder
A16. Yes.
A17. In the case of a remote financial services agreement:

a) the first payment under this agreement shall be made via an account kept in the customer's name held at a credit institution or a
foreign credit institution operating in the EU or EEA;
b) the customer shall submit to the entity a copy of a document verifying the existence of this account together with copies of the
relevant parts of his identity card and at least one more identification document to validate the customer's identification data of this
card i.e. the type, serial number, issuing country or institution and validity.
Reporting
A18. To the Financial analytical department (FAU) of the Police, the Ministry of Interior of the Slovak Republic
http://www.minv.sk/?financna-policia
.
Questions
A19. Volume and Answers:
of SARs:
2011 2,980 SARs

Q20. Are thereofany

Volume obligations to report anything more than suspicious transactions e.g. unusual transactions, cash transactions above a certain
SARs:
A19. threshold, international
2011 2,980 SARs wire transfers, other transactions etc.?

A20. The suspicious transaction are identified based on various criteria such as unusual transactions, cash transactions above a certain
threshold, international wire transfers etc. But no special report is required.
A21. No.
A20. The suspicious transaction are identified based on various criteria such as unusual transactions, cash transactions above a certain
threshold, international wire transfers etc. But no special report is required.
A22. Potential cash penalties up to EUR 332,000 (depending on the seriousness of the breach) or a suspension of business license for conscious
non-compliance within a 12- month period.
A21. No. there any requirements (legal or regulatory) to use automated Suspicious Transaction monitoring technology?
Are
Q23.
A23. No, however, transaction monitoring should be performed by using adequate means which assumes the use of some automated
technology.
Q22.
A22. Potential cash penalties up to EUR 332,000 (depending on the seriousness of the breach) or a suspension of business license for conscious
non-compliance
Is withinto
there a requirement a 12- month
obtain period.
authority to proceed with a current/ongoing transaction that is identified as suspicious?
Q24.
A24. Yes - in general a transaction that is identified/reported as suspicious can be continued after 48 hours from when it has to be notified to the
FAU, unless
Are there anythe FAU requires
requirements the transaction
(legal or regulatory)to to
beuse
postponed further
automated and FAUTransaction
Suspicious has passedmonitoring
the notification to criminal police (in which case
technology?
Q23. an additional 24hour delay is anticipated by law).
A23. No, however, transaction monitoring should be performed by using adequate means which assumes the use of some automated
technology.
A25. No.
Q24.
A24. Yes - in general a transaction that is identified/reported as suspicious can be continued after 48 hours from when it has to be notified to the
FAU, unless the FAU requires the transaction to be postponed further and FAU has passed the notification to criminal police (in which case
an additional 24hour delay is anticipated by law).
A25. No.
.
.
PwC helps
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to the PricewaterhouseCoopers
2012 PricewaterhouseCoopers. All rights reserved. accuracy or completeness of
eachliability,
of which is a separate
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dutyindependent legal
of care for any
contained
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consequences
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firms of

Russia
Key contact: Irina Novikova / Tatiana Postal address: Butyrsky Val 10, 125047 Last updated:
Vostrova Moscow January 2013
Email: irina.n.novikova@ru.pwc.com /
tatiana.vostrova@ru.pwc.com
Tel: +7 (495) 223-5086
General
A1. 2001.
A2. N/A.
A3. The Central Bank of the Russian Federation: www.cbr.ru/eng/

Federal Service of Financial Monitoring (FSFM): http://www.fedsfm.ru/ .
A4. No specific guidance although there have been various amendments to the federal AML law signed in 2001 (with the latest amendment
dated July 2012) and a number of recommendations and instructions issued by public authorities.
A5. No.
A6. Yes.
A7. The last mutual evaluation has been conducted in 2008:

http://www.fatf-gafi.org/topics/mutualevaluations/documents/mutualevaluationoftherussianfederation.html .
.
to the of another
network
member
of

A6. Yes.
Know
The last mutual evaluation has been conducted in 2008:
http://www.fatf-gafi.org/topics/mutualevaluations/documents/mutualevaluationoftherussianfederation.html .
A8. For legal entities, there is no specific threshold under which the due diligence is not required. For individuals the minimum threshold is set
as RUB15,000 (approx EUR 375).
.
However,
contained in this publication there
without are thresholds
obtaining above which
specific professional advice.compulsory
The applicationcontrol (which
and impact of lawsmeans
can vary report to regulator)
widely based is required,
on the specific forNoexample,
facts involved. when:
or implied) is given asa)
to thethe
accuracy
amountor completeness of the information
of transaction is equal contained in this publication,
to or exceeds RUB600,000 and, to the extent permitted
(approx by law, PricewaterhouseCoopers
EUR15,000) if it is in petty cash LLP, its members,
or wire transfer employees
to the and
payee located
publication or for any decision based on it. in countries which do not follow FATF recommendations, certain transaction with bank deposits, etc;
b) transactions with immovable assets if the amount is equal to or exceeds RUB3,000,000 (approx EUR75,000);
c) International
PricewaterhouseCoopers receipt ofLimited,
monetary
each offunds
which isor
RUB200,000 (approx. EUR5,000).
other assets
a separate by non-profit
and independent organisations from
foreign entities if the amount is equal to or exceeds
legal entity.
A9. Individuals: name, citizenship, personal identity document details, date of birth, migration card data, document confirming the foreign
citizen's or person's right to stay in Russia, residential (registration) address and taxpayer identification number (if any).
Corporates: name, taxpayer identification number or code of the foreign organisation, state registration number, registration address and
actual address.
A10. General requirement is that the copies of documents provided should be certified by an appropriate person, for example a Notary Public.
A11. Organisations shall take substantiated measures to establish and identify beneficiaries, and on a regular basis update information on clients
and beneficiaries.
A12. Individuals may be identified on the basis of the document certifying identity. There are some specific requirements, e.g. the transaction is
not complex or unusual in nature.
A13. Local regulations state that increased risk operations include: operations with residents of states mentioned in local guidance, operations
with international Politically Exposed Persons (PEPs) (and their close relatives), closure of transactions in real estate, performance of
banking operations and closure of other transactions with the use of internet technologies and operations with residents of states which do
not comply with generally accepted standards as identified through international sources.
A14. Local regulations state that international PEPs (and their close relatives) are subject to additional controls.
A15. Local regulations state that for the establishment of correspondent relations with non-resident banks, the institution shall request information
including full name, address, licence information, information about the presence or absence at its location of the legal entity etc. The
decision on the establishment of such relations shall be adopted with the consent of the head of the institution or of the institution's
employee as authorised to do so.

In what with shell
circumstances banks specifically
is additional prohibited?
due diligence required for non face-to-face transactions and/or relationships?
Q17.
A16. Yes.
None stated in local regulations.
A17.
.
Reporting
In what circumstances is additional due diligence required for non face-to-face transactions and/or relationships?
Q17.
Know
A17.
None stated in local regulations.
Reporting
A18. Federal Service of Financial Monitoring (FSFM): http://www.fedsfm.ru/.
A20. Companies are obliged to verify the source and report transaction if (also refer to A8 above)
a) the amount of transaction is equal to or exceeds RUB600,000 (approx EUR15,000) if it is in petty cash or wire transfer to the payee
located in countries which do not follow FATF recommendations, certain transaction with bank deposits, finance lease
arrangement, income from lottery, transactions with precious metals, etc.;
b) transactions with immovable assets if the amount is equal to or exceeds RUB3,000,000 (approx EUR75,000);
c) receipt of monetary funds or other assets by non-profit organisations from foreign entities if the amount is equal to or exceeds
RUB200,000 (approx EUR5,000).
d) any transaction in which the receiver or sender is located in a country which does not have AML legislation and which does not
cooperate with other countries in the area of AML, etc.
A21. Yes, see A20 above. However, the threshold should be applied by taking into consideration all other qualitative characteristics of
transactions and customers as stipulated by the AML law.
A22. Yes, but the amount and action (e.g., withdrawal of a licence) depends on the specific case.
A23. There are specific Instructions issued by FSFM on 5 October 2009 (with amendments of April 2012) in respect of suspicious transaction
reporting and in particular using electronic tool or special software for reporting.
A24. No.
Upon receipt of suspicious transaction report FSFM may verify the information reported by the company and if necessary pass on the
information to other competent government body for further consideration.
A25. Subject to local legislation and inter-governmental agreements.
.
www.pwc.com.
Romania
Key contact: Dan Dascalu Postal address: Last updated:
Email: dan.dascalu@david-baias.ro Lakeview Office, 301-311 Barbu Vacarescu Street, January 2013
Tel: +40 212 25 3770 RO-020276, Bucharest, Romania
General
A1. 2002. Law no. 656/2002 with its subsequent amendments, together with Guidance Notes issued through the Government Decision
No 496/2006 set out the local regulatory framework for the prevention and sanctioning of money laundering, as well as for establishing
measures for the prevention of and fight against financing terrorist acts, with subsequent amendments in 2006, 2007, 2008, 2009, 2010,
2011 and 2012.
A2. N/A.
A3. a) The National Office for Prevention and Control of Money Laundering (www.onpcsb.ro );
b) The National Office for Prevention and Control of Money Laundering and other specific institutions in their respective field of
activity National Bank of Romania (www.bnr.ro), National Insurance Commission (www.csa-isc.ro), National Securities
Commission (www.cnvmr.ro) and the Private Pension System Supervisory Commission (www.csspp.ro);
c) The National Office for Prevention and Control of Money Laundering.
A4. The National Office for Prevention and Control of Money Laundering organizes at least once a year training seminars regarding prevention
of money laundering and of financing of terrorist acts.
A5. No.
A6. Yes - the 2008 amendments established the standard, simplified and enhanced customer due diligence rules and procedures.
A7. http://www.coe.int/t/dghl/monitoring/moneyval/Evaluations/Progress%20reports%202y/MONEYVAL(2011)14_ProgRep2ROMann_en.pdf

.
2013 PwC.
accept reserved.
assumeNot
consequences refers
context requires,
on it.
network
exercise of member
member of

A6. Yes - the 2008 amendments established the standard, simplified and enhanced customer due diligence rules and procedures.
Questions
Q7. Has and been
the country Answers:
the subject of a FATF (or FATF-style) Mutual Evaluation or IMF assessment exercise in the last three years? If yes,
Know
A7.
http://www.coe.int/t/dghl/monitoring/moneyval/Evaluations/Progress%20reports%202y/MONEYVAL(2011)14_ProgRep2ROMann_en.pdf

.
contained in thisIf publication
Yes, what are obtaining
without the various thresholds
specific in place?
professional advice. The application and impact of laws can vary widely based on the specific facts involved. No representation or warranty (express
A8. Yes
publication or for any -decision
transactions
based on below
it. EUR15,000.
Individuals: need to provide the following details;

a) name;
b) surname;
c) citizenship; and
d) date of birth.
These details are normally verified by an identity card or passport.
Legal entities: need to provide the following details;

a) name;
b) identification; and
c) names and dates of birth of individual members of the statutory bodies (such as board of directors) or administrators.
This is normally verified by an official extract from The National Trade Registry Office which proves existence of the entity. This applies to
customers and real beneficiaries as well.
A10. Copies of provided documents can be certified by a notary public.
A11. Beneficial owners are subject to the following requirements:

a) identification of beneficial owners and the verification of their identity by taking risk-based and adequate measures;
b) gathering of information on the purpose and nature of the established business relationship; and
c) conducting continual monitoring of the business relationship with the respective customer.
A12. Simplified due diligence arrangements apply to:

a) domestic public authorities;
b) life insurance under the conditions mentioned in the law and subscription to pension funds;
c) electronic currency as defined by the regulations;
d) a credit or financial institution from an European Union (EU) member state or from the European Economic Area (EEA), or a
credit or financial institution from a non-EU state or from a state outside the EEA that imposes similar anti-money laundering and
fight against terrorist financing requirements and supervision; and
e) transactions and products that are low risk in respect to money laundering and financing of terrorist acts.
A13. Enhanced due diligence measures are required in the following cases:
a) non face-to-face transactions;
b) in the case of correspondent relationships with credit granting institutions from non-EU countries and those countries that are not
part of the EEA;
c) transactions or business relationships with politically exposed persons who are resident in another EU member state or in the
EEA, or in non-EU countries or countries outside the EEA; and
d) in any other cases where it is considered that due to their nature a high risk in respect of money laundering and financing of
terrorist acts is present.
.
A13. Enhanced due diligence measures are required in the following cases:
a) non face-to-face transactions;
b) in the case of correspondent relationships with credit granting institutions from non-EU countries and those countries that are not
Questions and Answers:part of the EEA;

c) transactions or business relationships with politically exposed persons who are resident in another EU member state or in the
EEA, or in non-EU countries or countries outside the EEA; and
d) in any other cases where it is considered that due to their nature a high risk in respect of money laundering and financing of
terrorist acts is present.
.
A14. Additional due diligence is required for transactions or business relationships with PEPs who are resident in another EU member state or in
the
contained in this EEA, orwithout
publication in non-EU
obtainingcountries or countries
specific professional advice. outside the EEA.
The application and impact of laws can vary widely based on the specific facts involved. No representation or warranty (express
Q15. What enhancedAlldue

2009 PricewaterhouseCoopers. rightsdiligence must be performed for
reserved. PricewaterhouseCoopers correspondent
refers banking
to the network of member
relationships
firms of

(cross-border banking and similar relationships)?
A15. Enhanced due diligence must be performed for cross-border correspondent banking relationships with credit institutions in third countries.
A16. Yes - the law specifies that credit institutions will not enter into correspondent relationships with a fictitious bank or with a credit institution
where it is known that it allows a fictitious bank to use its accounts.
A17. Additional due diligence is required for all non face-to-face transactions.
Reporting
A18. The National Office for Prevention and Control of Money Laundering:
http://www.onpcsb.ro/html/english.php
A19. Information on the volume of SARS is not publicly available.
A20. No.
A21. Transactions in cash over EUR15,000 must be reported.
A22. Non-compliance is considered a misdemeanour and certain sanctions may be applied for non compliance, ranging from fines to the closure
the entity breaching its obligation to report.
A23. There are regulatory requirements, applicable only to banks and other financial institutions.
.
A21. Transactions in cash over EUR15,000 must be reported.

A22. Non-compliance is considered a misdemeanour and certain sanctions may be applied for non compliance, ranging from fines to the closure
thecountry
Country by entity breaching its obligation
comparison to report.
of high level Know Your Customer and Anti-Money Laundering information
A23. There are regulatory requirements, applicable only to banks and other financial institutions.
. A24. Yes.
Q25. Does
publication or for the local
any decision legislation
based on it. allow transactions to be monitored outside the jurisdiction?
A25. International
Local persons whoLimited, each of which
are obliged is a separate
to report and independent
suspicious legal entity.
transactions may rely upon the
KYC checks made by third parties (banks and financial
institutions) from other Member States or from third countries applying KYC rules similar equivalent to Romania there in.
www.pwc.com.
.
Portugal
Portugal
Key contact: Manuel Luz Postal address: Last updated:
Key contact: Manuel Luz Postal address: Last updated:
Email: manuel.luz@pt.pwc.com Palacio Sottomayor; January 2013
Email: manuel.luz@pt.pwc.com Palacio Sottomayor; January 2013
Tel: +351 21 359 9304 Rua Sousa Martins 1-2; 1069-316;
Tel: +351 21 359 9304 Rua Sousa Martins 1-2; 1069-316;
Lisbon; Portugal
Lisbon; Portugal
General
General
A1. 1993 (amended 2004 and 2008).

A1. 1993 (amended 2004 and 2008).
A2. N/A.
A2. N/A.
A3. The regulator for AML controls for:

A3. The regulator for AML controls for:
a) Banking and other financial services are Banco de Portugal, Comisso do Mercado de Valores Mobilirios( CMVM) and Instituto
a) Banking and other financial services are Banco de Portugal, Comisso do Mercado de Valores Mobilirios( CMVM) and Instituto
Seguros de Portugal (ISP);
Seguros de Portugal (ISP);
b) Non financial sector are Servio de Inspeco de Jogos do Turismo de Portugal, Instituto da Construo e do Imobilirio, Autoridade
b) Non financial sector are Servio de Inspeco de Jogos do Turismo de Portugal, Instituto da Construo e do Imobilirio, Autoridade
de Segurana Alimentar e Econmica, Ordem dos Revisores Oficiais de Contas, Cmara dos Tcnicos Oficiais de Contas, Instituto
de Segurana Alimentar e Econmica, Ordem dos Revisores Oficiais de Contas, Cmara dos Tcnicos Oficiais de Contas, Instituto
dos Registos e do Notariado, Ordem dos Advogados and Cmara dos Solicitadores.
dos Registos e do Notariado, Ordem dos Advogados and Cmara dos Solicitadores.
Regarding the financial services regulators, the links are:
Regarding the financial services regulators, the links are:
Banco de Portugal http://www.bportugal.pt/en-US/Pages/inicio.aspx
Banco de Portugal http://www.bportugal.pt/en-US/Pages/inicio.aspx
CMVM http://www.cmvm.pt/en/Pages/default.aspx
CMVM http://www.cmvm.pt/en/Pages/default.aspx
ISP - http://www.isp.pt/NR/exeres/97C24D91-5FD7-4874-9D7D-FFE049D206D9.htm
ISP - http://www.isp.pt/NR/exeres/97C24D91-5FD7-4874-9D7D-FFE049D206D9.htm
A4. N/A.
A4. N/A.
A5. No - however, entities should retrospectively review documentation to identify customers, based on materiality and risk criteria, namely the
A5. No - however, entities should retrospectively review documentation to identify customers, based on materiality and risk criteria, namely the
characteristics of the account, the customer and the business relationship with the customer, in order to identify accounts that need an
characteristics of the account, the customer and the business relationship with the customer, in order to identify accounts that need an
immediate update.
immediate update.

A6. Yes - Law n25/2008, which transposes the Third Directive, provides that in compliance with identification and diligence duties, financial
A6. Yes - Law n25/2008, which transposes the Third Directive, provides that in compliance with identification and diligence duties, financial
institutions can adapt the nature and scope of the verification and diligence procedures, taking into account the risk associated with the type
institutions can adapt the nature and scope of the verification and diligence procedures, taking into account the risk associated with the type
of customer, the business relationship, the product, the transaction and the origin or the purpose of the funds.
of customer, the business relationship, the product, the transaction and the origin or the purpose of the funds.
A7. The last IMF Country Report was published in July 2012. The report is the fourth country review under the three-year arrangement under
A7. The last IMF Country Report was published in July 2012. The report is the fourth country review under the three-year arrangement under
the extended fund facility. The reports link is http://www.imf.org/external/pubs/cat/longres.aspx?sk=26072.0
the extended fund facility. The reports link is http://www.imf.org/external/pubs/cat/longres.aspx?sk=26072.0
The country page (Portugal and IMF) is http://www.imf.org/external/country/prt/index.htm.
The country page (Portugal and IMF) is http://www.imf.org/external/country/prt/index.htm.
There are no updated FATFs mutual evaluations.
There are no updated FATFs mutual evaluations.
. 2013 PwC. All rights reserved. Not for further distribution without the permission of PwC. PwC refers to the network of member firms of PricewaterhouseCoopers International Limited (PwCIL), or, as the

.context
This publication
requires, has been prepared
individual for general
member firms guidance
of the PwC on matters
network. of interest
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for any consequences of youand, to the extent
or anyone permitted
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or refraining LLP, its members,
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contained in this and
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agentsDesign
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based on it. responsibility or duty of care for any consequences of you or anyone else acting, or refraining to act, in reliance on the information contained in this
PricewaterhouseCoopers All rights
International reserved.
Limited, each ofPricewaterhouseCoopers refers to thelegal
which is a separate and independent
network of member firms of
entity.

A8. Yes - one-off transactions (single or linked) under EUR 15,000. For financial institutions, according to Instruo 26/2005 of Banco de
Portugal, the threshold is EUR12,500 (single or linked).
A9. Individuals: should provide a valid document with: full name, photo, tax identification number, address, profession and work place (when
applicable), politically exposed job/function, birth date and nationality.
Corporates: should provide a valid document with the headquarters address, identification number (should be made through the card
named Carto de Identificao de Pessoa Colectiva), shareholder identification if more than 25% of the voting rights, and board of directors
identification. For non-resident entities, equivalent documentation is required.
A10. The copies of documentation can be certified by external third parties such as notaries.
A11. Management Board and shareholder identification must occur if more than 25% of the voting rights are held. Identification and verification
requirements for beneficial owners are the same as those for individuals or companies listed above.
A12. Financial entities shall not be subject to the identification requirement where the customer is a financial entity set up in a European Union
Member State or in a third country which imposes equivalent requirements in respect of money laundering and terrorist financing prevention
and:
a) the customer is a listed company in a regulated market; or
b) the customer is the State or a Public Sector Company or Governmental Institute.
A13. Entities should apply enhanced due diligence measures, in respect of customers and transactions which by their nature or characteristics
can present a higher risk of money laundering or terrorist financing. This includes operations carried out with Politically Exposed Persons
('PEPs') residing outside the national territory, correspondent banking operations with credit institutions established in third countries and
any others designated by the competent supervisory or monitoring authorities.
A14. A non-resident PEP relationship requires additional due diligence. When establishing a relationship with a non-resident PEP, entities should
have appropriate risk-based procedures to determine whether the customer is a PEP; have senior management approval for establishing
business relationships with such customers; take adequate measures to establish the source of wealth and the source of funds that are
involved in the business relationship or occasional transaction and conduct enhanced ongoing monitoring of the business relationship.
A15. When establishing a relationship through correspondence with third country banks, this relationship must be approved by the senior
management. In addition, the financial institution should guarantee that customer identification was verified and the diligence duty was
observed.
.
Q16. Are
contained in this relationships
publication with shell
without obtaining banks
specific specifically
professional prohibited?
A16. Yes.
Know
Q16.
Yes.
A16.
A17. Non face-to-face relationships (especially those that can favour anonymity) require additional due diligence. In these cases, the institution
should demand additional documentation and ensure the first credit or debit is made through an account opened with the customer name.
Reporting
A18. Suspicious Activity Reports (SARs) are made to Policia Judiciaria - http://www.pj.pt/
A20. No.
A21. No.
A22. No.
A23. No.
A24. No.
A25. No.
.
2009 PricewaterhouseCoopers. All rights reserved. who are committed to delivering
quality
the network
tax and
of member advisory
firms of

Poland
Key contact: Damian Kalinowski Postal address: Last updated:
Email: damian.kalinowski@pl.pwc.com Aleja Armii Ludowej 14 January 2013
Tel: 519-507-197 00-638 Warszawa
General
A1. 2001 - although major changes to this legislation became effective in the first half of 2010, as a response to the requirement to implement
the Third European Union (EU) Directive in Poland. The status described below reflects the provisions of the new regulation.
A2. As noted above, major changes follow those amendments implemented in the Third EU Directive. Amongst other considerations, prior
regulation did not require the identification of ultimate beneficial owners, development of the risk rating model or identification of Politically
Exposed Persons (PEPs).
A3. All financial institutions are regulated by the General Inspector of Financial Information (Generalny Inspektor Informacji Finansowej) located
in the Ministry of Finance.
http://www.mf.gov.pl/en/aml-ctf/news
Additionally Polish Financial Supervision Authority (KNF) performs reviews of the adequacy of AML procedures.
www.knf.gov.pl
A4. The Polish Banking Association (ZBP) developed guidance concerning AML practices. The Regulator provides limited guidelines concerning
AML procedures which are published on the regulators website (see above)
A5. Yes.
A6. Yes.
A7. Yes -the Mutual Evaluation was conducted by MONEYVAL (http://www.coe.int/t/dghl/monitoring/moneyval/Countries/Poland_en.asp)
.
2013 PwC.
accept reserved.
assume Not
consequences refers
context requires,
on it.
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member

A6. Yes.
Questions
Q7. Has and been
Know
A7.
Yes -the Mutual Evaluation was conducted by MONEYVAL (http://www.coe.int/t/dghl/monitoring/moneyval/Countries/Poland_en.asp)
. If Yes, what are the various thresholds in place?
A8. Yesas- tointhe
or implied) is given limited circumstances
accuracy customer
or completeness of duecontained
the information diligence is not
in this required,
publication, e.g.
and, to for lifepermitted
the extent insurance
by law,below the threshold of
PricewaterhouseCoopers EUR1,000
LLP, its members,per year (or
employees and
agents do not accept or assume
EUR2,500 in any
caseliability,
of aresponsibility or duty of care
one off payment). for any
Lower consequences
thresholds of you orin
allowed anyone else acting,
relation or refraining
to electronic to act, in reliance
payments (EUR150on the for
information
regular contained
premiumsin this and
EUR2,500 for single premiums).
A9. Individuals: determining and noting the distinguishing features of a document confirming the persons identity pursuant to separate
regulations, or of a passport, as well as the first name, last name, the citizenship and address of the person executing the transaction, and
furthermore the PESEL (national citizens registry) number in the case of the identification on the basis of identity card or country code in the
case of the passport.
Legal entities: up-to date information from a court registry extract or other document specifying its name the organisational form of the
legal entity, its location, address and information from a valid document confirming the authority of the person executing the transaction to
represent the legal entity.
A10. Not stated in local regulations or guidance regarding external third party certification. Certification of copies of identification documents may
be made by a state authority, a notary public or a lawyer.
A11. Local guidance requires verification of the identity of appropriate beneficial owners holding 25% or more. Where a principal owner is another
corporate entity or trust, the firm should take measures to establish the identities of its beneficial owners or trustees, unless that company is
publicly traded. The firm will then judge which of the beneficial owners exercise effective control, and whose identities should therefore be
verified.
A12. Simplified due diligence arrangements may be applied for:

a) other financial services firms which are subject to the Money Laundering Regulations or equivalent, and which are regulated in
Poland by KNF (which is the Polish Financial Supervision Authority), or in the EU or a comparable jurisdiction by an equivalent
regulator;
b) central / local government entities; and
c) companies listed on regulated markets.
A13. Enhanced customer due diligence is required for:

d) a company engaged in activities that are assessed to carry a higher money laundering risk;
e) Politically Exposed Persons (PEPs);
f) the establishment of a non-face-to-face business relationship; and
g) a financial institution operating in jurisdictions where AML law is assessed as inadequate.
A14. Local guidance states that a PEP status puts a customer into the higher risk category. This implies enhanced due diligence is required for
every PEP.
.
e) Politically Exposed Persons (PEPs);
f) the establishment of a non-face-to-face business relationship; and
g) a financial institution operating in jurisdictions where AML law is assessed as inadequate.

In what circumstances are additional due diligence required for Politically Exposed Persons (PEPs)?
Q14.
Know
A14.
Local guidance states that a PEP status puts a customer into the higher risk category. This implies enhanced due diligence is required for
every PEP.
A15. Regulation requires that enhanced due diligence should involve further consideration of the following elements, designed to ensure that the
bank has secured a greater level of understanding with corresponding banks overseas (other than those based in the EU or other states
.
This publicationwith
has equivalent
been preparedAML regulations):
for general guidance on matters of interest for the personal use of the reader, and does not constitute professional advice. You should not act upon the information
a) ownership,
contained in this publication management
without obtaining and supervision
specific professional information;
b)to theAML/Terrorist
accuracy or completeness
Financing of the information
controls containedand
adopted; in this publication, and, to the extent permitted by law, PricewaterhouseCoopers LLP, its members, employees and
publication or for anyc)decision
senior
basedmanagement
on it. approval before entering into the relationship
A16. Yes.
A17. Establishment of a non face-to-face business relationship specifically requires additional due diligence. As a minimum, one of the following
actions is required:
a) verification of the customers identity against additional documents;
b) certification of copies of identification documents by an appropriate authority; or
c) confirmation that the customers initial transaction was made through a financial institution.
Reporting
A18. General Inspector of Financial Information:


2011 2,527 (General Inspector of Financial Information activity report for the year 2011)

2011 USD 514,496 million (Source: data.worldbank.org * )
This results in a ratio of 1 SAR for every USD 203.6 million of GDP.
A20. Yes, All transactions above the threshold of EUR15,000 (incl. related transactions with the aggregated amount above the threshold) should
be reported.
A21. Transactions below EUR15,000 do not need to be reported unless they are classified as suspicious.
.
Reporting
A20. Yes, All transactions above the threshold of EUR15,000 (incl. related transactions with the aggregated amount above the threshold) should
be reported.
Questions
Know
Q21.
General Inspector of Financial Information:
Transactions below EUR15,000 do not need to be reported unless they are classified as suspicious.
Country

A22. The Polish
2011 Anti-money
2,527 laundering
(General Inspector of act outlines
Financial fines or imprisonment
Information for non
activity report compliance
for the with reporting requirements.
year 2011)
GDPmaking
calculated without (in current prices):
deductions for depreciation of fabricated assets or for depletion *and degradation of natural resources. Data are in current U.S. dollars. Dollar figures for GDP are converted from
2011 using
domestic currencies USD 514,496
single million
year official (Source:
exchange rates. For a few countries where the)official exchange rate does not reflect the rate effectively applied to actual foreign exchange transactions, an
data.worldbank.org
Q23. Are there any requirements
alternative conversion factor is used. (legal or regulatory) to use automated Suspicious Transaction monitoring technology?
.
This
This publication has results in a ratio
been prepared of 1 guidance
for general SAR foronevery
mattersUSD 203.6
of interest million
for the of use
personal GDP.of the reader, and does not constitute professional advice. You should not act upon the information
A23. No.
Q20. Are there any obligations to report anything more than suspicious transactions e.g. unusual
thattransactions, cash transactions above a certain
Q24. Is there a requirement
threshold,International
PricewaterhouseCoopers international
to obtain
wire
Limited,
authority to proceed
transfers,
each of which is aother transactions
separate
with
refers
and independent
a current/ongoing
to the
etc.?
transaction
is identified as
network of member firms
legal entity.
of suspicious?

A24. Suspicious transactions reported to the regulator should be suspended for 24 hours. If the regulator does not request further suspension of
a transaction,
Yes, it can be
All transactions processed.
above BasedofonEUR15,000
the threshold the regulators
(incl.request
related atransactions
transaction with
can be
thesuspended
aggregatedoramount
account blocked
above the for further 72
threshold) should
A20. hours.
be A prosecutor can suspend a transaction or block an account for up to 3 months.
reported.
Q21. Are
Doesthere
the any
localde-minimis
legislation thresholds below which
allow transactions to betransactions do not the
monitored outside need to be reported?
jurisdiction?
Q25.
A21. Transactions
The Polish Actbelow EUR15,000 do
on Counteracting ofnot needLaundering
Money to be reported
and unless theythe
Financing areTerrorism
classified(the
as suspicious.
Act) provides that, as a rule, it is the Polish
A25. General Inspector of the Financial Information that is officially authorised to monitor the transactions. However, bearing in mind that the Act
implements the EU regulations (that should have been implemented by all Member States), it is likely that a transaction may be subject to
monitoring outside Poland, on the basis stipulated by the local law of the foreign party of the transaction, especially in cases where a given
Q22. Are there any
transaction is penalties
performedforwith
nonorcompliance with
via a foreign reporting requirements e.g. tipping off?
entity.
.
www.pwc.com.
This publication has been prepared for general the
guidance on matters
information of interest
contained in thisfor the personal
publication use of
without the reader,
obtaining and does
professional advice.professional advice. or
No representation You should (express
warranty not act upon the information
contained vary
warranty or (express
assume
responsibility contained in this
duty of care forpublication, and, to the
you or permitted
acting, LLP, itson
the information and
contained
Norway
Key contact: Helge Kvamme Postal address: Last updated:
Email: helge.kvamme@no.pwc.com P.O.Box 748 Sentrum, N-0106 Oslo, January 2013
Tel: +47 95 26 1270 Norway
General
A1. 2009 (15 April 2009). A new Circular No. 8/2009 was published by the Financial Supervisory Authority of Norway on 23 June 2009.
A2. Customer identification and verification of authentication.
A3. For a) and b): Finanstilsynet (The Financial Supervisory Authority of Norway) - http://www.finanstilsynet.no/en
A4. Yes, guidance by The Financial Supervisory Authority of Norway Circular no 8/2009 -
http://www.finanstilsynet.no/no/Artikkelarkiv/Rundskriv/2009/2-kvartal/Veiledning-til-ny-lov-og-forskrift-med-tiltak-mot-hvitvasking-og-
terrorfinansierin
A5. Yes.
A6. Yes - risk based customer due diligence and monitoring customer relationships on an ongoing basis.
A7. Yes, latest report was 26 February, 2009 - http://www.fatf-gafi.org/dataoecd/9/52/43209579.pdf .
A8. No.
.
2013 PwC.
accept reserved.
assumeNot
consequences refers
context requires,
on it.
network
exercise of member
member of

A9. Individuals: a natural person's identity is normally verified by producing a document issued by a public authority, which normally contains
full name, signature, photograph and personal identity number or D-number (non-residents liable to pay tax are registered with a unique D-
number). Examples of suitable documents include a passport, bank card and driving licence.
Corporates: a legal person's identity is verified by Certificate of Registration/Certificate of Incorporation from the Public Register.
A10. Normally, the establishment of non-face-to-face business relationships is not allowed and the customer must physically appear either at the
reporting financial institution or at an agent or outsource company, where identification and verification is performed. Copies can be certified
in exceptional circumstances and must be verified by authorised persons, including postal employees, the police and lawyers.
A11. The Money Laundering Act (MLA) requires financial institutions to verify the identity of beneficial owners on the basis of reasonable
measures. The MLA defines beneficial owners generally as the natural persons who ultimately own or control the customer and/or on
whose behalf a transaction or activity is being carried out. The definition is then further elaborated to describe five situations where a person
in all cases is to be regarded as a beneficial owner.
A12. Norway has introduced simplified customer due diligence procedures. If a customer or transaction falls into specific cases, simplified
customer due diligence will apply, such as:
a) financial undertakings listed in the Money Laundering Regulations;
b) a financial institution in the European Union (EU) and European Economic Area (EEA), and their correspondent financial
institutions, which are compliant with the relevant FATF Recommendations;
c) a financial institution listed or regulated in an EEA state or a financial institution subject to disclosure requirements consistent with
those that apply to listing on a regulated market in an EEA state; and
d) a Norwegian state or municipal administrative body.
A13. The MLA requires financial institutions to apply other customer due diligence measures, in addition to the basic customer due diligence
measures stipulated in the MLA in the following cases:
a) situations that by their nature involve a high risk of transactions associated with proceeds of crime or certain designated offences
listed in the Criminal Code (including terrorist financing and terrorism offences);
b) business relationships and transactions with Politically Exposed Persons (PEPs); and
c) correspondent banking relationships.
A14. Reporting entities are required to conduct appropriate customer due diligence measures to verify whether the customers are PEPs. Such
measures include:
a) obtaining approval from senior management before establishing a customer relationship;
b) taking appropriate measures to ascertain the origin of the customers assets and of capital involved in the customer relationship or
the transaction; and
c) carrying out enhanced ongoing monitoring of the relationship.
.
Questions and
A14. Reporting
measures Answers:
entities are required to conduct appropriate customer due diligence measures to verify whether the customers are PEPs. Such
include:

a)
obtaining approval from senior management before establishing a customer relationship;
b)
taking appropriate measures to ascertain the origin of the customers assets and of capital involved in the customer relationship or
the transaction; and
Country by country comparison
c) carrying of high
out enhanced level
ongoing Know of
monitoring Your Customer and Anti-Money Laundering information
the relationship.
A15. When establishing cross-border correspondent banking relationships with institutions outside the EEA area, institutions are required to:
a) gather sufficient information concerning the correspondent institution to fully understand the nature of its activities and, on the
basis of publicly available information, to determine the reputation of the institution and the quality of supervision;
b) assess the institutions control measures;
c) ensure that the decision maker obtains approval from senior management before establishing a new correspondent relationship;
. d) document the respective responsibilities; and
e) prepared
This publication has been ascertain that the
for general correspondent
guidance institution
on matters of interest for the conducts
personal useongoing monitoring
of the reader, ofconstitute
and does not customers.professional advice. You should not act upon the information
Q16. Are relationships All with shell banks specifically prohibited?
2009 PricewaterhouseCoopers. rights reserved. PricewaterhouseCoopers refers to the network of member firms of
A16. No.
A17. The former requirement of face-to-face relationships is replaced by the implementation of risk based customer due diligence and ongoing
monitoring of customer relationships.
Reporting
A18. To KOKRIM;
The National Authority for Investigation and Prosecution of Economic and Environmental Crime in Norway
http://www.okokrim.no/artikler/in-english

2010 6,660

A20. International wire transfers, foreign exchange and foreign credit and debit card transactions are reported to the:
Foreign Exchange, Foreign Currency Register with the Norwegian Directorate of Customs and Excise
A21. No.
*
.
A18. To KOKRIM;wire transfers, foreign exchange and foreign credit and debit card transactions are reported to the:
International
A20. The National
Foreign Authority
Exchange, for Investigation
Foreign and Prosecution
Currency Register of Economic
with the Norwegian and Environmental
Directorate Crime
of Customs in Norway
and Excise
http://www.okokrim.no/artikler/in-english
Know
Q21.
Q19.
A21. byNo.
Volume of SARs:
A19. 2010 6,660
Q22. GDP (in current prices):
Yes, breaches of the Money Laundering Act can be punished with fines or imprisonment for up to 1 year when special aggravating
A22. circumstances exists.
*
Q23. Are there
Are there anyobligations
any requirements (legal
to report orFor
regulatory)
anything
a few more tothan
usesuspicious
automated Suspicious
transactions Transaction
e.g. unusual monitoring
effectively technology?
transactions, cash transactions abovetransactions,
a certainan
Q20.
domestic currencies using single
threshold,
alternative conversion
year official exchange
factorinternational
is used.
rates. countries
wire transfers, other transactions etc.?
where the official exchange rate does not reflect the rate applied to actual foreign exchange
.
A23.
This publicationYes, financial
has been preparedinstitutions have an
for general guidance onobligation according
matters of interest to the use
for the personal Moneyof the Laundering Act
reader, and does notto use electronic
constitute professionalsuspicious transaction
advice. You should monitoring
not act upon the information
systems.
International wire transfers, foreign exchange and foreign credit and debit card transactions are reported to the:
A20.
agents do notForeign Exchange,
accept or assume Foreign
any liability, Currency
responsibility Register
or duty of care forwith the Norwegian
any consequences of youDirectorate
or anyone elseof Customs
acting, andtoExcise
or refraining act, in reliance on the information contained in this

2009 PricewaterhouseCoopers. to obtain
All rights reserved. authority to proceed
PricewaterhouseCoopers with
refers a current/ongoing
to the transaction
network of member firms
of

that is identified as suspicious?
A24. Yes, as the principal rule, suspicious transactions shall not be proceeded before a report is made to the FIU (KOKRIM). KOKRIM can
decide that the actual transaction shall not be effected.
A21. No.
A25. Not mentioned in the regulations.
*
.
www.pwc.com.
professional advice.professional advice. You
No representation should not
or warranty act upon
contained vary
does do not or accept
warrantyor(express
assume
you orpermitted by law,
acting, LLP, its on
the information and
contained
Netherlands
Key contact: Andre Mikkers Postal address: Thomas R. Malthusstraat Last updated:
Email: andre.mikkers@nl.pwc.com 5, 1066 JR January 2013
Tel: +31 88 792 6348 Postbus 9616, 1006 GC
Amsterdam
General
A1. 1993 (amended 2003). Revised legislation as per July 2008.
A2. N/A
A3. a) De Nederlandsche Bank (DNB): www.dnb.nl

b) DNB and Autoriteit Financile Markten (AFM): www.afm.nl
c) DNB, tax authorities (www.belastingdienst.nl) and Bureau Financieel Toezicht (BFT): www.bureauft.nl
A4. a) www.dnb.nl
b) www.afm.nl
c) www.belastingdienst.nl; www.bureauft.nl
A5. No.
A6. Yes.
A7. The latest report from the FATF is dated February 2011: http://www.fatf-gafi.org/dataoecd/3/59/47221499.pdf
A8. Yes Customer Due Diligence is not required for cash transactions under EUR15,000 for institutions overseen by the tax authorities or in
. the case of incidental relationships, for institutions overseen by the BFT.
2013 PwC.
agents do notAll rights reserved.
accept Not
distribution without the permission
for any of PwC. PwC of refers to
or the network
elseofacting,
member firms of PricewaterhouseCoopers International Limited (PwCIL),
in this or, as the
Q9.
context What orare
requires,
assume
the high liability,
level
of therequirements
or duty of verification
for care consequences
member firm is a of customer you anyone
identification or refraining
and does not information
to act, in reliance
(individuals on theentities)?
andmember
legal information contained
on it. PwC network. Each separate legal entity act as agent of PwCIL or any other firm. PwCIL does not provide any services
responsible
A9. Individuals
can be Limited,
International identified eachby
of any other
passport
of which or other
is a separate
refers the
and identification
network
exercise
independent legaldocument.
of member
of another
entity.
firms firms
member of

Companies have to be identified by extracts from the Chamber of
Commerce or by notary deed. Copies have to be made and archived in files. There are no additional requirements stated in local regulations
or guidance, except for companies or clients outside the Netherlands.
Yes Customer Due Diligence is not required for cash transactions under EUR15,000 for institutions overseen by the tax authorities or in
A8. thecountry
case of incidental relationships, for level
institutions overseen by the BFT. and Anti-Money Laundering information
Country by comparison of high Know Your Customer
A9. Individuals can be identified by passport or other identification document. Companies have to be identified by extracts from the Chamber of
Commerce or by notary deed. Copies have to be made and archived in files. There are no additional requirements stated in local regulations
or guidance, except for companies or clients outside the Netherlands.
A10. Notary deeds are required for companies and persons abroad, except for US and UK citizens.
A11. Ultimate Beneficial Owners need to be identified for legal entities - their identity needs to be verified based on independent, reliable
documents. Both identification and verification can be performed in a risk-based manner.
A12. Based on the risk profile of the client, products, services and client-product combination.
A13. Based on the risk profile of the client, products, services and client-product combination.
A14. For PEPs resident in other states.
A15. Enhanced due diligence is required for all correspondent banking relationships outside the EU, whereby a number of factors need to be
taken into account including, but not limited to:
(a) gather sufficient information to obtain a full picture of the nature of the banks activities;
(b) evaluate reputation of bank and quality of oversight based on publically available information; and/or
(c) evaluate procedures and measures to prevent money laundering and terrorist financing.
A16. It is forbidden to enter into a correspondent banking relationship with a shell bank. In addition it is not allowed to enter into or continue a
correspondent banking relationship with a credit institution that allows shell banks to use their accounts.
A17. Identification in person is not obligatory in all circumstances. In summary, payment of the services has to be done from a bank account.
There are no additional requirements in local regulations or guidance. If identification cannot be done face-to-face this is regarded a high
risk, which needs to be adequately mitigated.
.
Reporting
Q18. To whom
or implied) is given as to theare Suspicious
accuracy Activity
or completeness Reports
of the (SARs)
information made?
contained in this Please include
publication, a link
and, to the topermitted
extent their website.
by law, PricewaterhouseCoopers LLP, its members, employees and
A18. Financial Intelligence Unit-Nederland: www.fiu-nederland.nl

2010 183,395 SARs
A18. Financial Intelligence Unit-Nederland: www.fiu-nederland.nl

Reporting

A18. by2010 Financial Intelligence Unit-Nederland: www.fiu-nederland.nl
183,395 SARs
2010 183,395 SARs
GDP
Are (in current
there prices): to report anything more than suspicious transactions e.g. unusual transactions, cash transactions above a certain
any obligations
Q20. 2010 USD779,356
threshold, million
international (Source: data.worldbank.org
wire transfers,
*
)
other transactions etc.?
A20. Both objective and subjective indicators are applicable which do not only cover suspicious transactions.
Q21. Are there any
threshold, de-minimiswire
international thresholds below
transfers, otherwhich transactions
transactions etc.? do not need to be reported?
A21. There are several different thresholds in place for a variety of objective indicators. There is no threshold for subjective indicators.
A20. Both objective and subjective indicators are applicable which do not only cover suspicious transactions.
A22. There are penalties for non-compliance with the legal requirements.
A21. There are several different thresholds in place for a variety of objective indicators. There is no threshold for subjective indicators.
A23. No.
A22. There are penalties for non-compliance with the legal requirements.
A24. No.
A23. No.
A25. Monitoring of the business relationship needs to be performed by the institution itself.
A24. No.
A25. Monitoring of the business relationship needs to be performed by the institution itself.
.
publication prices isbased
or for any decision the sumon of
it. gross value added by all resident producers in the economy plus any product taxes and minus any subsidies not included in the value of the products. It is
domestic
currencies using single year official
alternative conversion factor
reserved.
exchangePricewaterhouseCoopers
rates. For a few countriesrefers
wheretothe
theofficial
network
is used. Limited, each of which is a separate and independent legal entity.
of member
exchange ratefirms
doesofnot reflect the rate effectively applied to actual foreign exchange transactions, an
.
www.pwc.com.
Luxembourg
Key contact: Rima Adas / Roxane Haas Postal address: Last updated:
Email: rima.adas@lu.pwc.com / 400 route d'Esch, L-1471 Luxembourg, January 2013
roxane.haas@lu.pwc.com Luxembourg
Tel: +352 49 48 48 2101/2451
General
A1. 1993 (amended 2004, 2008 and 2010).
A2. The Law effective 27/10/ 2010 comes as a consequence of the recommendations made by the FATF in early 2010. This Law reinforces and
clarifies the previous legislation.
A3. The regulators for AML are as follows:

For SARs: the Financial Intelligence Unit (FIU) of the Luxembourg Public Prosecutors.
For the supervision of particular industries:
a) Banking : CSSF(Commission de Surveillance du Secteur Financie) http://www.cssf.lu/en/
b) Other financial services: CSSF http://www.cssf.lu/en/
c) Non financial sector: lawyers (barrister of the Bar)
A4. No However a practical guide for the funds industry is in discussion and should be published in 2012 on the ALFI website (Association of the
Luxembourg Fund industry) (http://www.alfi.lu/ ).
A5. Yes.
A6. Yes.
A7. Yes - http://www.fatf-gafi.org/countries/j-m/luxembourg/documents/mutualevaluationofluxembourg.html
.
PricewaterhouseCoopers refersthe exercise
to the of another
network
member
of

A6. Yes.
Questions
Q7. Has and been
Know
A7.
Yes - http://www.fatf-gafi.org/countries/j-m/luxembourg/documents/mutualevaluationofluxembourg.html
.
A8. Yesastoone-off
or implied) is given transactions
the accuracy (single
or completeness of theor linked) contained
information under EUR15,000.
in this publication, and, to the extent permitted by law, PricewaterhouseCoopers LLP, its members, employees and
Q9. What areInternational
the high Limited, each of which is afor
level requirements separate and independent
verification legal entity.
of customer identification information

A9. Individuals: A copy (or certified true copy in the case of non face-to-face business) of an official identification document, for example a
passport or identity card. Documents need to be reliable and might be provided by the customer but not produced by himself ('independent
source'). If no copy is kept, the professional has to state in the account opening form: surname, first name, date of birth, address,
profession and identification document number. The account opening form has to be dated and signed by the customer.
Corporates: Articles of Association (or equivalent), extract of the Commercial Register (or equivalent), business authorisation if the entity
manages funds of third parties, identification of the beneficial owners holding over 25% and of the persons with authorised signatures.
A10. If non face-to-face business is conducted, the copy should be certified as true by a competent authority, for example a consulate, embassy,
police station or notary. By law, the customer information needs to be based on documents or data coming from reliable and independent
sources.
A11. There is an obligation in the law to verify the identity of beneficial owners. Those who hold 25% or more of a corporate entity have to be
identified. Where a principal owner is another corporate entity or trust, the firm should take measures to look behind that company or trust
and establish the identities of its beneficial owners or trustees, unless that company is publicly quoted. The firm will then judge which of the
beneficial owners exercise effective control, and whose identities should therefore be verified.
A12. Simplified due diligence arrangements are listed in Article 3-1 of the Luxembourg AML Law. Examples of simplified due diligence
arrangements include:
a) where the customer is a credit or financial institution subject to equivalent AML regulations and which is supervised;
b) on certain conditions, pooled accounts held by notaries and other legal independent professionals;
c) where the customer is a Luxembourg public authority;
d) insurance policies for pension schemes if there is no surrender clause and the policy cannot be used as collateral;
e) pension schemes that provide retirement benefits to employees, where contributions are made by way of deduction from wages
and the scheme rules do not permit the transfer of rights; and
f) where the customer is a listed company whose securities are admitted to trading on a regulated market within the meaning of
Article 1-11 of the law of 13 July 2007 in one or more European Union ('EU') Member States or a listed company in a third country
subject to disclosure requirements consistent with EU legislation.
A13. Enhanced customer due diligence measures are required in situations which by nature present a higher risk of money laundering or terrorist
financing and at least in the cases listed in Article3-2 of the Luxembourg AML Law (for example non face-to-face business, foreign Politically
Exposed Persons ('PEPs') and cross-frontier correspondent banking relationships with respondent institutions from non EU countries).
A14. Enhanced customer due diligence measures are required for foreign PEPs, including the implementation of an appropriate risk-based
procedure to detect such foreign PEPs, involving the senior management in the customer's acceptance, ascertaining the source of
wealth/income and ensuring an enhanced ongoing monitoring of the relationship.
.
A13. Enhanced customer due diligence measures are required in situations which by nature present a higher risk of money laundering or terrorist
financing and at least in the cases listed in Article3-2 of the Luxembourg AML Law (for example non face-to-face business, foreign Politically
Exposed Persons ('PEPs') and cross-frontier correspondent banking relationships with respondent institutions from non EU countries).

Know
Enhanced customer due diligence measures are required for foreign PEPs, including the implementation of an appropriate risk-based
procedure to detect such foreign PEPs, involving the senior management in the customer's acceptance, ascertaining the source of
wealth/income
Country by and ensuring an
country comparison ofenhanced
high levelongoing
Know monitoring of the relationship.
A15. For correspondent banking relationships, the professionals have to:

.
a) gather sufficient information about the respondent institution to understand fully the nature of the respondent's business and to
contained in this publicationdetermine fromspecific
without obtaining publicly available
professional information
advice. theand
The application reputation of the
impact of laws institution
can vary andonthe
widely based thequality of supervision;
specific facts involved. No representation or warranty (express
b)to theassess
or implied) is given as accuracythe respondentof institution's
or completeness the information AML andin CTF
contained controls;
this publication, and, to the extent permitted by law, PricewaterhouseCoopers LLP, its members, employees and
c) obtain approval from senior management before establishing new correspondent banking relationships;
d) document the respective responsibilities of each institution; and
e) with respect to payable-through accounts, be satisfied that the respondent credit institution has checked the identity of and
performed ongoing due diligence on the customers having direct access to the accounts of the correspondent and that it is able to

provide relevant customer due diligence data to the correspondent institution upon request.
A16. Yes - it is prohibited to enter into, or continue a correspondent banking relationship with a shell bank or with a bank that is known to permit
its accounts to be used by a shell bank.
A17. Enhanced customer due diligence measures are required for non face-to-face businesses. These include :
a) obtaining additional documents, data or information that ensures adequate identification of customers; or
b) performing additional measures to verify or certify the identification documents (for example, copies of identification documents
certified true by a credit or financial institution or by a competent authority); or
c) first payment to be drawn on an account opened in the customer's name with a credit institution.
Reporting
A18. Financial Intelligence Unit (FIU) of the Luxembourg Public Prosecutors (http://www.justice.public.lu/fr/actualites/2010/09/rapport-activite-
crf/index.html).

2010 4,866 SARs

A20. No.
A21. No -all suspicious transactions, regardless of the amount, have to be reported.
.
This-results
Yes in a ratiotoofenter
it is prohibited 1 SAR fororevery
into, USD11
continue million of GDP.
a correspondent banking relationship with a shell bank or with a bank that is known to permit
A16. its accounts to be used by a shell bank.
Questions
Q20. Are thereand Answers:
any obligations to report anything more than suspicious transactions e.g. unusual transactions, cash transactions above a certain

A17. Enhanced
No. customer due diligence measures are required for non face-to-face businesses. These include :
A20. a) obtaining
Country by country additional documents,
comparison dataKnow
of high level or information that ensuresand
Your Customer adequate identification
Anti-Money of customers;
Laundering or
information
b) performing additional measures to verify or certify the identification documents (for example, copies of identification documents
certified true by a credit or financial institution or by a competent authority); or
c) first payment to be drawn on an account opened in the customer's name with a credit institution.

Reporting
Q22. Arewhom
To there any
pricesare
is thepenalties
sum of grossfor
Suspicious non
value
Activitycompliance
added with
by all resident
Reports (SARs) reporting
producers
made? in therequirements
economy
Please plus anye.g.
include tipping
aproduct
link taxes
to off?
andwebsite.
their minus any subsidies not included in the value of the products. It is
Q18.
A22. Offenders
alternative conversion
Financialfactor who knowingly
is used.
Intelligence Unit violate
(FIU) AML/CTF legislationPublic
of the Luxembourg could Prosecutors
face a fine up to EUR1.25 million and those guilty of professional negligence
(http://www.justice.public.lu/fr/actualites/2010/09/rapport-activite-
.A18. could face administrative and disciplinary sanctions.
crf/index.html).
Q23. Are there
What was any requirements
the volume (legal
of SARs madeor regulatory) to use in
to the authorities automated Suspicious
the most recent year?Transaction monitoring
Please state the GDP technology?
for the equivalent year.
Q19.
A23. There isof
Volume noSARs:
legal or regulatory obligation to use automated Suspicious Transaction monitoring technology. However, it is highly
A19. recommended
2010 by the authorities to implement such a tool (CSSF circular 08/387).
4,866 SARs

*
2010 USD53,334
Is there million
a requirement (Source:
to obtain data.worldbank.org
authority to proceed with) a current/ongoing transaction that is identified as suspicious?
Q24.
A24. Professionals must refrain from carrying out a transaction which they know or suspect to be related to money laundering or terrorist
financing before having informed the FIU. The FIU can give instructions not to execute one or more operations relating to the transaction or
the customer. Where a transaction is suspected of giving rise to money laundering or terrorist financing and where to refrain in such manner
is impossible
Are there any or is likely totofrustrate
obligations efforts tomore
report anything pursue the
than beneficiaries
suspicious of a suspected
transactions moneytransactions,
e.g. unusual laundering orcash
terrorist financingabove
transactions operation, the
a certain
Q20. professionals
threshold, concerned
international shall
wire submit the
transfers, necessary
other information
transactions etc.? immediately afterwards.
A20. No.
A25. In practice, because of professional confidentiality the monitoring of transactions is not performed outside the jurisdiction. However, credit
institutions
Are andde-minimis
there any professionals of the financial
thresholds sector
below which forming part
transactions doofnot
a financial group
need to be shall guarantee to the groups internal control bodies,
reported?
Q21. where necessary, access to information concerning specific business relations, to the extent that this is needed for the global management
of legal risks and risks to their reputation in connection with money laundering or the financing of terrorism within the meaning of the laws of
Luxembourg.
.
www.pwc.com.
.
Jersey
Jersey
Key contact: Mark James
Key contact: Mark James Postal address:
Postal address: Last updated:
Last updated:
Key contact:
Email: Mark James
mark.james@je.pwc.com Postal address:
Twenty Two Colomberie
Colomberie Last updated:
January 2013
Email: mark.james@je.pwc.com Twenty Two January 2013
Email:
Tel: mark.james@je.pwc.com
+44 (0) 1534 838304 Twenty
St Two
Helier, Colomberie
Jersey JE1 4XA
4XA January 2013
Tel: +44 (0) 1534 838304 St Helier, Jersey JE1
Tel: +44 (0) 1534 838304 St Helier,
Channel Jersey
Islands JE1 4XA
Channel Islands
Channel Islands
General
General
General
Q1. In what
In what year
year did
did the
the relevant
relevant AML
AML laws
laws and
and regulations
regulations become
become effective?
effective?
Q1.
A1. The Proceeds
The Proceeds of of Crime
Crime (Jersey)
(Jersey) Law
Law was
was issued
issued in
in 1999.
1999. It
It is
is supplemented
supplemented by by the
the Money
Money Laundering
Laundering (Jersey)
(Jersey) Order
Order 2008
2008 and
and the
the
A1. Handbook
The for
Proceeds the
of Prevention
Crime and
(Jersey) Detection
Law was of Money
issued in Laundering
1999. It is and the
supplemented Financing
by the of Terrorism.
Money Laundering (Jersey) Order 2008 and the
A1. Handbook for the Prevention and Detection of Money Laundering and the Financing of Terrorism.
Handbook for the Prevention and Detection of Money Laundering and the Financing of Terrorism.
Q2. If the
If the AML
AML laws
laws and/or
and/or regulations
regulations became
became effective
effective in
in the
the last
last 2
2 years,
years, what
what were
were the
the requirements
requirements of
of the
the previous
previous AML
AML regime?
regime?
Q2.
A2. The Order
The Order and
and the
the Handbook
Handbook issued
issued in
in February
February 2008
2008 updated
updated existing
existing subordinate
subordinate legislation
legislation and
and detailed
detailed guidance
guidance which
which supported
supported the
the
A2. 1999 law. and the Handbook issued in February 2008 updated existing subordinate legislation and detailed guidance which supported the
The Order
A2. 1999 law.
1999 law.
Q3. Who is
Who is the
the regulator
regulator for
for AML
AML controls
controls for:
for: (a)
(a) Banking;
Banking; (b)
(b) Other
Other financial
financial Services;
Services; (c)
(c) Non
Non financial
financial sector
sector (e.g.
(e.g. casinos,
casinos, high
high value
value goods
goods
Q3. etc.).
Who is Please include for
the regulator linkAML
to the
the regulator(s)
controls website.
for: (a) Banking; (b) Other financial Services; (c) Non financial sector (e.g. casinos, high value goods
Q3. etc.). Please include link to regulator(s) website.
A3. Jersey Financial

Jersey Financial Services
Services Commission
Commission (www.jerseyfsc.org)
(www.jerseyfsc.org)
A3. Jersey Financial Services Commission (www.jerseyfsc.org)
A3.
Q4. Is there
Is there any
any practical
practical guidance
guidance provided
provided to
to firms
firms by
by public
public authorities
authorities regarding
regarding AML
AML requirements,
requirements, beyond
beyond the
the FATF
FATF recommendations
recommendations and
and
Q4. local legislation?
Is there Please
any practical includeprovided
guidance link to
to website,
website, where
to firmswhere available.
by public authorities regarding AML requirements, beyond the FATF recommendations and
Q4. local legislation? Please include link available.
A4. Yes
Yes the
the AML
AML Handbook
Handbook has
has specific
specific guidance
guidance for
for industries
industries on
on the
the application
application of
of AML
AML requirements.
requirements. For
For example
example the
the AML
AML Handbook
Handbook for
for
A4. the accountancy
Yesaccountancy sector. http://www.jerseyfsc.org/pdf/Consolidated_Version_AML_HBK_July_2010.pdf
the AML Handbook http://www.jerseyfsc.org/pdf/Consolidated_Version_AML_HBK_July_2010.pdf
has specific guidance for industries on the application of AML requirements. For example the AML Handbook for
A4. the sector.
the accountancy sector. http://www.jerseyfsc.org/pdf/Consolidated_Version_AML_HBK_July_2010.pdf
Q5. Is there
Is there a
a requirement
requirement to
to retrospectively
retrospectively verify
verify the
the identity
identity of
of customers
customers before
before the
the date
date the
the new
new AML
AML regime
regime was
was introduced?
introduced?
Q5.
A5. No -- however,
No however, businesses
businesses are
are required
required to
to apply
apply customer
customer due
due diligences
diligences measures
measures to
to existing
existing customers
customers at
at appropriate
appropriate times.
times.
A5. No - however, businesses are required to apply customer due diligences measures to existing customers at appropriate times.
A5.
Q6. Is a
Is a risk
risk based
based approach
approach approved
approved by
by the
the local
local regulator(s)?
regulator(s)?
Q6.
A6. Yes -- the
Yes the Handbook
Handbook was
was issued
issued and
and effective
effective on
on 44 February
February 2008
2008 for
for regulated
regulated financial
financial services
services businesses.
businesses. The
The answers
answers below
below are
are taken
taken
A6. from
Yes -that
the guidance.
Handbook On
was19 February
issued and 2008, customer
effective on 4 due diligence
February 2008 requirements
for regulated were extended
financial to
services lawyers, accountants,
businesses. The answersestate agents
from that guidance. On 19 February 2008, customer due diligence requirements were extended to lawyers, accountants, estate agentstaken
below are and
A6. others.
from that guidance. On 19 February 2008, customer due diligence requirements were extended to lawyers, accountants, estate agents and
and
others.
others.
Q7. Has the

Has the country
country been
been the
the subject
subject of
of a
a FATF
FATF (or
(or FATF-style)
FATF-style) Mutual
Mutual Evaluation
Evaluation or
or IMF
IMF assessment
assessment exercise
exercise in
in the
the last
last three
three years?
years? If
If yes,
yes,
Q7. please find
Has thefind a link
linkbeen
country to a
a relevant
relevant report
the subject (ifFATF
of a(if publicly available).
(or available).
FATF-style) Mutual Evaluation or IMF assessment exercise in the last three years? If yes,
Q7. please a to report publicly
A7. Yes
Yes 2008
2008 IMF
IMF assessment.
assessment. Available
Available publically
publically on
on JFSC
JFSC website.
website.
A7. Yes 2008 IMF assessment. Available publically on JFSC website.
A7.
Customer due
diligence
Q8. Are there
Are there minimum
minimum transaction
transaction thresholds,
thresholds, under
under which
which customer
customer due
due diligence
diligence is
is not
not required?
required?
Q8. If
AreYes, what
there are the
the transaction
minimum various thresholds
thresholds in place?
place?
thresholds, under which customer due diligence is not required?
Q8. If Yes, what are various in
.
.
A8.
This publication Yeshas -been
one-off transactions
prepared (singleonor
for general guidance linked)
matters underforEUR15,000.
of interest the personal use of the reader, and does not constitute professional advice. You should not act upon the information
.
This publication
publication without for generalspecific
obtaining guidance on mattersadvice.
professional of interest
The for the personal
application use of the
and impact reader,
of laws canandvarydoes notbased
widely constitute professional
on the advice.
specific facts You should
involved. not act uponorthe
No representation information
warranty (express
This publication
contained in this has been prepared
publication without for generalspecific
The for the personal
application use of the
and impact reader,
of laws can and
varydoes notbased
on the advice.
specific facts You No
involved. should not act upon
representation orthe information
warranty (express
or implied)
contained is
in given
this as to the
publication accuracy
without or completeness
obtaining of the information
specific professional contained
advice.contained in
The application this publication,
and impact of and, to
laws the
can extent permitted
vary widely based by law,
on PricewaterhouseCoopers
thePricewaterhouseCoopers
specific facts involved. No LLP, its members,
representation employees
oremployees and
warranty (express
or
agents do not accept or assume any liability, responsibility or duty of care for any consequences of you or anyone else acting, or refraining to act, in reliance on the information contained in this and
implied) is given as to the accuracy or completeness of the information in this publication, and, to the extent permitted by law, LLP, its members,
or implied)
agents is given
do not accept asortoassume
the accuracy or completeness
any liability, of the
responsibility information
or duty of care contained in this publication,
for any consequences of you and, to the else
or anyone extent permitted
acting, by law, PricewaterhouseCoopers
or refraining LLP, its members,
to act, in reliance on the information containedemployees
in this and
publication
2013 PwC.
agents do not or for
All any
rights
accept decision
reserved.
or assume based
Not on
for it.
further
any liability, distribution without the permission of PwC. PwC refers to the network of member firms of PricewaterhouseCoopers International Limited (PwCIL), or, as the
publication or for
What any decision
are thebased
high it. responsibility
onlevel requirements or duty of care for any consequences of you or anyone else acting, or refraining to act, in reliance on the information contained in this
for verification of customer identification information (individuals and legal entities)?
Q9.
context requires,
publication individual member
or for any decision based firms
All on
of the PwC network. Each member firm is a separate legal entity
it. reserved. PricewaterhouseCoopers refers to the network of member firms of and does not act as agent of PwCIL or any

other member firm. PwCIL does not provide any services

to
clients.
responsible
2009 PricewaterhouseCoopers. International
All
Individuals:
rights
or liable
rightsfor
rights
acts or omissions
Limited,
name,Limited,
reserved.
Limited,
of any
address
each
each ofPricewaterhouseCoopers
reserved.other member
of which
each and
is a firm
date
nor can
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Noindependent
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firms of

of another member firms professional judgment or bind another member firm or PwCIL in any way.
legal entity.
legal entity. are mandatory, but local issued guidance dictates that evidence of
A9.
International of which separate
identity should be obtained from documents issued by reputable sources. Separate verification of address is also required.
Legal Entities: Minimum evidence expected is one of:

Yes - one-off transactions (single or linked) under EUR15,000.
A8.
A9. Individuals: name, address and date of birth. No specific documents are mandatory, but local issued guidance dictates that evidence of
identity should be obtained from documents issued by reputable sources. Separate verification of address is also required.
Legal Entities: Minimum evidence expected is one of:

a) original or certified copy of the certificate of incorporation and memorandum and Articles of Association;
b) company registry search;
c) latest audited financial statements;
d) independent data sources, including electronic sources; and
e) personal visit to principle place of business.
In circumstances where information is not already publically available/ held, minimum requirements are to verify the identity of directors or
similar persons who have authority to operate a relationship or give instructions concerning the use/transfer of assets. Verification of other
directors and beneficial owners should also be considered depending on the risk profile.
A10. Where non face-to-face identification and verification is carried out, a certified copy of the identification documentation is required (by a
Notary Public or other qualified professional able to legally certify documents).
A11. Beneficial owners and controllers must be identified including at a minimum, those holding 25% or more interest in the capital of the entity
extending to those with a material interest depending on the risk profile. Reasonable measures must also be taken to obtain verification
documentation depending upon the risk profile of the entity.
A12. Reduced and simplified arrangements are available for identification and verification procedures of institutions in equivalent jurisdictions and
publically traded companies. There is also some scope for reliance to be placed on procedures already conducted by intermediary regulated
institutions.
A13. Enhanced measures are required for those potential clients deemed to be of higher risk. This might take into account factors such as
Politically Exposed Persons ('PEPs') risk, client not physically present for identification purposes, correspondent banking relationships,
jurisdictional risk and types of activity.
A14. Additional due diligence, enhanced scrutiny and monitoring is required on all accounts that have links with PEPs but particularly those with
links to countries that are vulnerable to corruption.
A15. Statutory requirements specifically identify correspondent banking relationships as a trigger for enhanced measures. Specific measures
suggested by the guidance include obtaining further identification information, commissioning due diligence reports from independent
experts and requiring higher levels of management approval for new clients.
. Yes - the Money Laundering (Jersey) Order 2008 contains prohibitions on relationships with shell banks.
A16.
Additional measures are required for relationships established or transactions conducted remotely, or where the identity of an individual is to
A17. be verified using documentary evidence when the individual is not physically present. Issued guidance suggests that certified copies of
verification documents such as passports should be obtained which have been certified by a 'suitable certifier'.
A16. Yes - the Money Laundering (Jersey) Order 2008 contains prohibitions on relationships with shell banks.
A17. Additional measures are required for relationships established or transactions conducted remotely, or where the identity of an individual is to
be verified using documentary evidence when the individual is not physically present. Issued guidance suggests that certified copies of
verification documents such as passports should be obtained which have been certified by a 'suitable certifier'.
Reporting
A18. Jersey Financial Crimes Unit (www.jersey.police.uk/FinancialCrime)

2011 1,847 SARs
GDP data is only available for the Channel Islands as a whole.
A20. Whilst there in no specific legal requirement, there is guidance for specific industries (for example, high value goods dealers) on unusual
transactions, cash transactions, wire transfers etc. This is part of the AML handbook.
A21. No.
A22. Yes There are penalties for Failure to report, Assisting and Tipping Off.
A23. No.
A24. Yes authorisation is required to proceed if transactions are identified as suspicious.
A25. Not currently.
.
www.pwc.com.
Italy
Italy
Keycontact:
Key contact:Fabrizio
FabrizioSantaloia
Santaloia//Elisa
ElisaFrancesconi
Francesconi Postaladdress:
Postal address: Lastupdated:
Last updated:
Email: fabrizio.santaloia@it.pwc.com/
Email: fabrizio.santaloia@it.pwc.com/ ViaMonte
Via MonteRosa
Rosa91,
91, January 2013
January 2013
elisa.francesconi@it.pwc.com
elisa.francesconi@it.pwc.com 20149Milano,
20149 Milano,Italy
Italy
Tel:+390
Tel: +390227785550/
7785550/5784
5784
General
General
Q1. Inwhat
In whatyear
yeardid
didthe
therelevant
relevantAML
AMLlaws
lawsand
andregulations
regulationsbecome
becomeeffective?
effective?
Q1.
A1. 1991(amended
1991 (amended2004,
2004,2006,
2006,2007,
2007,2009
2009and
and2010)
2010)
A1.
Q2.
Q2. IfIfthe
theAML
AMLlaws
lawsand/or
and/orregulations
regulationsbecame
becameeffective
effectiveininthe
thelast
last22years,
years,what
whatwere
werethe
therequirements
requirementsofofthe
theprevious
previousAML
AMLregime?
regime?
A2. N/A
N/A
A2.
Q3. Whoisisthe
Who theregulator
regulatorfor
forAML
AMLcontrols
controlsfor:
for:(a)
(a)Banking;
Banking;(b)
(b)Other
Otherfinancial
financialServices;
Services;(c)
(c)Non
Nonfinancial
financialsector
sector(e.g.
(e.g.casinos,
casinos,high
highvalue
valuegoods
goods
Q3. etc.).Please
etc.). Pleaseinclude
includelink
linkto
tothe
theregulator(s)
regulator(s)website.
website.
A3. FinancialIntelligence
Financial IntelligenceUnit
Unit(i.e.
(i.e.Unit
Unitdidiinformazione
informazionefinanziaria)
finanziaria)
A3. http://www.bancaditalia.it/UIF
http://www.bancaditalia.it/UIF
Q4.
Q4. IsIsthere
thereany
anypractical
practicalguidance
guidanceprovided
providedto
tofirms
firmsby
bypublic
publicauthorities
authoritiesregarding
regardingAML
AMLrequirements,
requirements,beyond
beyondthe
theFATF
FATFrecommendations
recommendationsand
and
locallegislation?
local legislation?Please
Pleaseinclude
includelink
linkto
towebsite,
website,where
whereavailable.
available.
A4. Yes-guidelines
Yes- guidelinesfor
forOrganization
Organizationand andInternal
InternalControls
Controlsfor
forAML
AMLpurposes
purposes
A4. (http://www.bancaditalia.it/vigilanza/normativa/norm_bi/disposizioni-vig/Provv_Organizz.pdf))and
(http://www.bancaditalia.it/vigilanza/normativa/norm_bi/disposizioni-vig/Provv_Organizz.pdf andawaiting
awaitingthe
theGuidelines
Guidelinesfor
forKYC
KYCRules
Rulesfor
for
Bankingand
Banking andFinancial
Financialsector
sector(http://www.bancaditalia.it/vigilanza/cons-pubblica/proc_in_corso/cons-prov23-12-2009/Provvedimento-sul-
(http://www.bancaditalia.it/vigilanza/cons-pubblica/proc_in_corso/cons-prov23-12-2009/Provvedimento-sul-
adeguata-verifica-della-clientela-Documento-per-la-consultazione.pdf).).
adeguata-verifica-della-clientela-Documento-per-la-consultazione.pdf
Q5.
Q5. IsIsthere
thereaarequirement
requirementto
toretrospectively
retrospectivelyverify
verifythe
theidentity
identityof
ofcustomers
customersbefore
beforethe
thedate
datethe
thenew
newAML
AMLregime
regimewas
wasintroduced?
introduced?
A5. Yes--banks,
Yes banks,financial
financialinstitutions,
institutions,non-financial
non-financialbusinesses
businessesand
andprofessionals
professionalshave
havetotoverify
verifythe
theidentity
identityof
ofcustomers
customersininthe
thecase
caseof
of
A5. transactions,aanew
transactions, newrelationship
relationshipor oras
assoon
soonas
asthey
theycome
comeinto
intocontact
contactwith
withthe
thecustomer.
customer.
Q6.
Q6. IsIsaarisk
riskbased
basedapproach
approachapproved
approvedby
bythe
thelocal
localregulator(s)?
regulator(s)?
A6. TheItalian
The Italiansystem
systemprovides
providesstrict
strictand
anddetailed
detailedprovisions
provisionson onanti-money
anti-moneylaundering
launderingand
andterrorist
terroristfinancing
financingrequirements.
requirements.In
Ingeneral,
general,ititisis
A6. possibleto
possible toassign
assignthese
theseobligations
obligationsononthe
thebasis
basisof
ofrisk
risk(the
(therisk
riskbased
basedapproach
approachbecame
becameeffective
effectiveininDecember
December2007).
2007).
Q7. Hasthe
Has thecountry
countrybeen
beenthe
thesubject
subjectof
ofaaFATF
FATF(or(orFATF-style)
FATF-style)Mutual
MutualEvaluation
Evaluationor
orIMF
IMFassessment
assessmentexercise
exerciseininthe
thelast
lastthree
threeyears?
years?IfIfyes,
yes,
Q7. pleasefind
please findaalink
linkto
toaarelevant
relevantreport
report(if
(ifpublicly
publiclyavailable).
available).
A7. No--the
No thelast
lastassessment
assessmentwas
wasperformed
performedinin2006.
2006.
A7.
Customer due
diligence
..
Thispublication
This publicationhas hasbeen
beenprepared
preparedforforgeneral
generalguidance
guidanceon onmatters
mattersofofinterest
interestfor
forthe
thepersonal
personaluse useofofthe
thereader,
reader,and
anddoes
doesnotnotconstitute
constituteprofessional
professionaladvice.
advice.You
Youshould
shouldnotnotact
actupon
uponthe
theinformation
information
containedininthis
contained thispublication
publicationwithout
withoutobtaining
obtainingspecific
specificprofessional
professionaladvice.
advice.The
Theapplication
applicationand andimpact
impactofoflaws
lawscan
canvary
varywidely
widelybased
basedon onthe
thespecific
specificfacts
factsinvolved.
involved.NoNorepresentation
representationororwarranty
warranty(express
(express
ororimplied)
implied)isisgiven
givenasastotothe
theaccuracy
accuracyororcompleteness
completenessofofthe theinformation
informationcontained
containedininthis
thispublication,
publication,and,
and,totothe
theextent
extentpermitted
permittedby bylaw,
law,PricewaterhouseCoopers
PricewaterhouseCoopersLLP, LLP,its
itsmembers,
members,employees
employeesand and
2013
agentsdo
agents PwC.
donot All rights
notaccept reserved.
acceptororassume
assumeanyNot for further
anyliability, distribution
liability,responsibility without
responsibilityororduty the permission
dutyofofcare
carefor
forany of PwC.
anyconsequencesPwC refers
consequencesofofyou to the
youororanyonenetwork
anyoneelse of member
elseacting, firms of
acting,ororrefraining PricewaterhouseCoopers
refrainingtotoact,
act,ininreliance
relianceon
onthe International
theinformation Limited
informationcontained (PwCIL),
containedininthis
this or, as the
context requires,
publication or individual
for any member
decision based
publication or for any decision based on it.firmson of
2009
PricewaterhouseCoopersInternational
All
All rights
rights
InternationalLimited,
reserved.
reserved.
Limited,each
eachofofwhich
whichisisaaseparate
separateand
refers
refers to
andindependent
to the
the
independentlegal
network
network of
of
legalentity.
entity.
member
member firms
firms of
of

A6. The Italian system provides strict and detailed provisions on anti-money laundering and terrorist financing requirements. In general, it is
possible to assign these obligations on the basis of risk (the risk based approach became effective in December 2007).
Questions
Q7. Has and been
Know
A7.
No - the last assessment was performed in 2006.
.
This publicationYes - one-off
has been transactions
prepared belowonEUR15,000
for general guidance (other
matters of interest than
for the where
personal use there are two
of the reader, and or more
does such transactions
not constitute which
professional advice. Youthe firm
should notbelieves are
act upon the linked
information
A8.
andaswhich together would amount
or implied) is given to the accuracy or completeness of theto EUR15,000
information or more)
contained and EUR1,000
in this publication, and, to thefor cash
extent and bearer
permitted instruments.
by law, PricewaterhouseCoopers LLP, its members, employees and
Q9. What areInternational
PricewaterhouseCoopers the high Limited,
level requirements
each of which is afor verification
separate of customer
and independent identification information
legal entity.
A9. Any person who:

a) opens, changes or closes a current, savings or deposit account or has another continuing relationship; or
b) carries out a single transaction, or several transactions which appear to be linked, involving the transmission, handling or the transfer
of means of payment or bearer instruments in an amount of EUR15,000 or more; must be identified and must indicate in writing the
full details of the person, if any, on whose behalf the transaction is carried out. Identification must take place each time a transaction
is executed.
Individuals evidence of identity should be obtained such as name, address, date and place of birth, tax code and a government issued
document e.g. an identity card, passport or driving licence.
Corporates evidence of identity of the firm, as well as the identity of the person physically present at the transaction, should be obtained
such as the company name, registrar office, tax code and evidence of the identity of the beneficial owner.
A10. Financial institutions, designated non-financial businesses and professionals cannot rely on a copy of an identification document. An
exception is provided for copies validated by public officers.
A11. Joint stock companies are required to publish lists of their shareholders and lists of persons who hold rights on securities. This information is
available to the authorities and to the public upon request (including online). In Italy, it is compulsory to provide all information regarding
beneficial ownership of transactions/relationships.
A12. Other than for telephone and internet banking, there are specific provisions allowing for simplified due diligence. Customer due diligence is
not required in the following cases:
a) transactions and account relationships between financial institutions;
b) the transfer of funds within the state treasury and payments arranged by the public administration, through the State Treasury, with
the exception of payment operations linked to the national debt;
c) the accounts, deposits and other continuing relationships between provincial sectors of State treasuries, the Bank of Italy and the
Financial Intelligence Unit (FIU); and
d) account relationships and transactions between banks, other licensed intermediaries that have their head office or branch in Italy and
banks or branches located abroad. This exemption applies regardless of whether the countries in which the banks/branches are
located, effectively implement the FATF Recommendations.
A13. There are specific provisions requiring enhanced due diligence for higher risk categories of customers, operations or transactions such as
financial products distributed via the internet, companies incorporated in a tax haven or a country listed on the OSCE (Organisation for
Security and Co-operation in Europe) grey list.
A14. The FIU has performed specific analysis on the money laundering aspect of foreign Politically Exposed Persons (PEPs) including a study
of aggregate financial flows to offshore institutions. When significant anomalies are identified, the FIU has the authority to request detailed
individual transaction information for analytical purposes from an institutions database (AUI), and has done so.
.
A15. For correspondent banking relationships, banks, financial and non financial institutions as well as professionals have to perform an
enhanced due diligence and acquire information as provided by the public register. In addition, where possible, they must evaluate the
internal control system of their correspondent bank and can only start the business relationship with the authorisation and responsibility of
top management.
A16. Yes - there are specific provisions that prohibit financial institutions from entering into or continuing correspondent banking relationships with
shell banks. Moreover, there are specific provisions that prohibit financial institutions from establishing relations with respondent foreign
financial institutions that permit their accounts to be used by shell banks.
A17. The Decalogo of the Bank of Italy requires financial intermediaries to adopt special precautions for transactions relating to telephone or
electronic accounts, and to take steps to ensure adequate knowledge of the customer and his business in cases of relationships with
customers in non face-to-face situations.
Reporting
A18. The SAR must be reported to the Financial Intelligence Unit (i.e. Unit dInformazione Finanziaria - UIF), which is a special agency of the
Banking Supervisory Authority (Banca dItalia).

1st semester 2012 34,458 SARs.
A20. There is an obligation to report all financial transactions above EUR 3,000 made by credit card or e-payment, but this is not specifically for
AML purposes - this type of report is made to the tax agency (Agenzia delle Entrate).
A21. See answer to Q20 above.
A22. Yes. There is a penal sanction for tipping off.
A23. Yes - legal and regulatory requirements require automated STR (suspicious transaction reporting) technology but only for e-banking and
home banking transactions.
.
A20. There is an obligation to report all financial transactions above EUR 3,000 made by credit card or e-payment, but this is not specifically for
AML purposes - this type of report is made to the tax agency (Agenzia delle Entrate).

Know
See answer to Q20 above.

Country
A22. Yes. There is a penal sanction for tipping off.
A23. Yes - legal and regulatory requirements require automated STR (suspicious transaction reporting) technology but only for e-banking and
home banking transactions.
.
Q24. Is publication
contained in this there a requirement
without obtainingtospecific
obtain authorityadvice.
professional to proceed with a
The application current/ongoing
and transaction
impact of laws can vary that
widely based is identified
on the specific factsas suspicious?
involved. No representation or warranty (express
A24. Yes
publication or for anydecision
it is a legal
based requirement
on it. under D. Lgs. 231/07 (Executive Order issued to implement the 2005/60 Directive).
A25. No.
www.pwc.com.
Isle of Man
Key contact: Jonathan Whiting Postal address: Last updated:
Email: jonathan.d.whiting@iom.pwc.com Sixty Circular Road; 3rd Floor; January 2013
Tel: +44 (0) 1624 689689 Douglas IM1 1SA; Isle of Man
General
A1. The Proceeds of Crime Act 2008 became fully effective in 2009. In 2011, the Anti-Terrorism and Crime (Amendment) Act 2011 was
introduced. The acts are supplemented by the Proceeds of Crime (Money Laundering) Code 2010, and the Prevention of Terrorist
Financing Code 2011 for entities regulated by the Financial Supervision Commission, the Insurance (Anti-Money Laundering) Regulations
2008 for entities regulated by the Insurance and Pensions Authority, and the Proceeds of Crime (Money Laundering Online Gambling)
Code 2010 and Prevention of Terrorist Financing (Online Gambling) Code 2011 for e-gaming entities regulated by the Gambling
Supervision Commission.
A2. The previous regime was similar (introduced in 1998). An update in 2008 effectively introduced the requirements of the European Union
(EU) Third Money Laundering Directive and the 2010 update brought regulations into line with the Proceeds of Crime Act 2008.
A3. The Financial Supervision Commission FSC is the regulator for banks, investment businesses, fiduciary service providers, collective
investment schemes, e-money providers and money transmission services (http://www.gov.im/fsc/).
The insurance and pensions sector is regulated by the Insurance and Pensions Authority IPA (http://www.gov.im/ipa/).
The gaming industry is regulated by the Gambling Supervision Commission GSC (http://www.gov.im/gambling/).
A4. The FSC provides guidance in the form of the Anti-Money Laundering and Countering the Financing of Terrorism Handbook
(http://www.gov.im/fsc/handbooks/guides/AML/).
The IPA provides guidance on money laundering and terrorist financing in the Guidance Notes on Anti-Money Laundering and Preventing
the Financing of Terrorism for Insurers (http://www.gov.im/ipa/insurance/regulations/insurancemoneylaundering.xml).
Guidance Notes on the Prevention of Money Laundering and Countering of Terrorist Financing are provided by the GSC covering the online
gambling industry (http://www.gov.im/gambling/licensing/).
A5. Customer due diligence requirements apply to existing and continuing business only when a trigger event has occurred as per paragraph 7
of the Proceeds of Crime (Money Laundering) Code 2010.
A6. Yes this has been effective from 2008.
.
context requires,
on it.
exercise
of member
member of

A7. The IMF last carried out a visit in 2009 (http://www.gov.im/lib/docs/fsc//detailedassessmentofobservanceof.pdf).
A8. There is no requirement to verify the identity of the customers if the transaction qualifies as an exempted one-off transaction, defined as a
single transaction or a series of linked transactions which has an (aggregate) value of less than:
a) EUR3,000 for holders of Casino licences and bookmakers (but excluding e-gaming businesses);
b) EUR1,000 for bureaux de change, money transmission services or cheque encashment facilities; or
c) EUR15,000 in all other cases.
A9. Individuals: The elements of identity which must be verified comprise:

a) for all customers, their name and date of birth and permanent residential address; and
b) for standard and higher risk customers, their nationality, place of birth, gender and official identification number.
Legal Entities: For all companies that are not listed on a recognised stock exchange (or their wholly owned subsidiaries), the elements of
identity which must be verified comprise:
a) name;
b) official identification number;
c) date and country of incorporation;
d) registered office address of the legal person; and
e) address of the principal place of business where this is different to the registered office.
A10. Suitable persons to certify verification of identity documents include:

a) a member of the judiciary, a senior civil servant, or a serving police or customs officer;
b) an officer of an embassy, consulate or high commission of the country of issue of documentary verification of identity;
c) a lawyer or notary public who is a member of a recognised professional body;
d) an actuary who is a member of a recognised professional body;
e) an accountant who is a member of a recognised professional body;
f) a company secretary who is a member of a recognised professional body;
g) a director, company secretary or manager of a business regulated on the Isle of Man or an external regulated business as defined
in the Code.
A11. In all cases, it is a requirement to identify underlying principals and/or beneficial owners at the outset of the business relationship,
irrespective of the geographical origin of the client, or of any introducer or fiduciary.
A12. There are no simplified due diligence provisions in the Code.
If a customer qualifies as an Acceptable Applicant, it is not necessary to verify their identity. Acceptable applicants are:
a) a regulated person in the Isle of Man or a nominee company of that regulated person;
b) a lawyer or accountant carrying out business in or from the Isle of Man, where the relevant person is satisfied that the rules of the
professional body of the applicant for business embody requirements and procedures that are at least equivalent to the Code;
c) a person who acts in the course of external regulated business and is regulated under the law and regulations of a country that is
on the FSC list of equivalent jurisdictions to the Isle of Man or a nominee company of that external regulated business; or
. d) a company listed on a recognised stock exchange or a wholly owned subsidiary of such a company.
A13. Where in accordance with the risk assessment, an applicant for business poses a higher risk, the relevant person must carry out enhanced
customer due diligence.
A12. There are no simplified due diligence provisions in the Code.
If a customer qualifies as an Acceptable Applicant, it is not necessary to verify their identity. Acceptable applicants are:
a) a regulated person in the Isle of Man or a nominee company of that regulated person;
b) a lawyer or accountant carrying out business in or from the Isle of Man, where the relevant person is satisfied that the rules of the
Questions and Answers: professional body of the applicant for business embody requirements and procedures that are at least equivalent to the Code;

c) a person who acts in the course of external regulated business and is regulated under the law and regulations of a country that is
on the FSC list of equivalent jurisdictions to the Isle of Man or a nominee company of that external regulated business; or
d) a company listed on a recognised stock exchange or a wholly owned subsidiary of such a company.
A13. Where in accordance with the risk assessment, an applicant for business poses a higher risk, the relevant person must carry out enhanced
customer due diligence.
A14. A relevant person must maintain appropriate procedures and controls for the purpose of determining whether any of the following is a
PEP:
a) an applicant for business;
b) a customer;
c) any natural person having power to direct the activities of an applicant for business or a customer;
d) the beneficial owner of an applicant for business or a customer; or
e) a known beneficiary of a legal arrangement.
A relevant person must maintain appropriate procedures and controls for requiring the approval of its senior management before any
business relationship is established with a PEP; or before any one-off transaction is carried out with a PEP; or where it is discovered that an
existing business relationship is with a PEP, before continuing that relationship.
A15. Before entering into a business relationship or one-off transaction involving correspondent banking services or other similar arrangements,
banks must take additional steps to the customer due diligence requirements as per Paragraph 13 of the Code as follows:
a) obtain sufficient information about the respondent bank to understand fully the nature of its business;
b) determine from publicly available information the respondent bank's reputation and quality of supervision including whether it has
been subject to a money laundering or terrorist financing investigation or regulatory action;
c) assess the respondent bank's AML/CFT procedures and controls, and ascertain that they are adequate and effective;
d) obtain senior management approval, i.e. sign off before establishing new correspondent banking relationships; and
e) document the respective AML/CFT responsibilities of the licence holder and the respondent bank.
A16. Yes.
A17. Where the licence holder deals with an applicant for business otherwise than face-to-face, it must take adequate measures to compensate
for any risk arising as a result.
Reporting
.
A18. Isle of Man Financial Crime Unit FCU (http://www.gov.im/fcu/st_reports/)
2010 1,442 SARs
A20. No.
A18.
Volume of SARs:
A19.
2010 1,442 SARs

A20. No.
A21. No.
A22. Under the Proceeds of Crime Act 2008, the penalty for failure to report is a fine and/or a prison sentence of up to five years. The penalty for
tipping off is a fine and/or a prison sentence of up to two years.
A23. No.
A24. Consent is required from the FCU to proceed with a current/ongoing transaction that is identified as suspicious.
A25. Yes.
1
.
www.pwc.com.
Ireland
Key contact: Iarla Power Postal address: Last updated:
Email: iarla.power@ie.pwc.com One Spencer Dock; North Wall Quay; January 2013
Tel: +353 (0) 1 7926398 Dublin 1; Ireland
General
A1. 2010 (the Criminal Justice (Money Laundering and Terrorist Financing) Act (Act).
A2. The previous regulations did not facilitate a risk-based approach. Different levels of CDD & ongoing monitoring was not a requirement
etc.).Please include link to the regulator(s) website.
A3. For regulated entities: Central Bank of Ireland
For Auditors, External Accountants, Tax Advisers, Trust or Company Service Providers, Private Members' Gaming Clubs, High Value
Goods Dealers. The Department of Justice and Equality Anti-Money Laundering Compliance Unit (AMLCU)
A4. Industry guidance notes have been prepared by a committee representing various sectors of the financial services industry.
The Core Guidelines have been drafted jointly by various sectors of the financial services industry. The guidelines are stated to be for the
purpose of guiding designated persons on the application of Part 4 of the Criminal Justice (Money Laundering and Terrorist Financing) Act
2010. While these guidelines have not been approved under Section 107 of the Act, the Central Bank will have regard to these guidelines in
assessing compliance by designated persons with the Act.
Links to the various guidelines can be located via: http://www.finance.gov.ie/viewdoc.asp?DocId=-1&CatID=16
A5. CDD in relation to existing customers must be conducted where:

a) The designated body has reasonable grounds to doubt the veracity or adequacy of documents or information previously
obtained;
b) There are doubts concerning previously obtained customer identification data.
A6. The Act provides expressly for risk-based measures to be applied by designated persons.
A7. The last evaluation conducted by FATF was on 17 Feb 2006: http://www.fatf-gafi.org/dataoecd/63/29/36336845.pdf .
.
to the of another
network
member
of

A8. In relation to occasional transaction where the total amount of money paid by the customer in a single transaction or series is greater than
EUR15,000; For more information see A12 (SCDD).
A9. The Act specifies in section 33(2)(a) that the measures to be applied under section 33(1) of the Act include identifying the customer, and
verifying the customers identity on the basis of documents (whether or not in electronic form), or information, that the designated person
has reasonable grounds to believe can be relied upon to confirm the identity of the customer, including
a) documents from a government source (whether or not a State government source), or
b) any prescribed class of documents, or any prescribed combination of classes of documents
The Guidance states that the following information should be obtained and verified:
Individuals:
Name, Date of Birth and Current Address
Documentary Verification
One plus One approach one item from the list of photographic IDs (typically to verify name and date of birth) and one item from the list of
non-photographic IDs (typically to verify address).
Photographic ID: Non Photographic ID:

Current valid Passport Official documentation/cards issued by the Revenue Commissioners and
Current valid driving licence; addressed to the individual;
Current valid National Identity Official documentation/cards issued by the Department of Social and Family Affairs
Card; and addressed to the individual;
Instrument of a court appointment (such as liquidator, or grant of probate);
Current local authority document e.g. refuse collection bill, water charge bill
(including those printed from the internet);
Current statement of account from a credit or financial institution, or credit/debit
card statements (including those printed from the internet);
Current utility bills; (including those printed from the internet);
Current household/motor insurance certificate and renewal notice.
Entities:
Customer
Name, legal form & proof of existence; address of registered office and main place of business; the nature of the business and its ownership
and control structure) and Directors or equivalent (Either two directors or one director and one authorised signatory)
Beneficial Owner extent of verification as warranted by the risk
Documentary verification
a) A search of the relevant company or other registry; or
b) A copy, as appropriate to the nature of the entity, of the certificate of incorporation, a certificate of good standing, a partnership
agreement, a deed of trust, or other official documentation proving the name, form and current existence of the customer.
c) In cases regarded by the Designated Person as higher risk, use of more than one source of information may be warranted.
d) obtaining a copy of the annual audited accounts listing directors
A10. The Guidance states that the following, and potentially their equivalents in other jurisdictions, are considered suitable persons to certify
documentation, where they are willing to do so:
a) Garda Siochana/ Police Officer
b) Practising Chartered & Certified Public Accountants
c) Notaries Public / Practising solicitors
d) Embassy/Consular Staff
e) Regulated financial or credit institutions
f) Justice of the peace
g) Commissioner for oaths
. h) Medical professional

2009 PricewaterhouseCoopers. levelreserved.
All rights requirements around beneficial
PricewaterhouseCoopers ownership
refers to (identification
the network of
member firms ofand verification)?
documentation, where they are willing to do so:
a) Garda Siochana/ Police Officer
b) Practising Chartered & Certified Public Accountants
c) Notaries Public / Practising solicitors
d) Embassy/Consular Staff
e)
f)
Regulated financial or credit institutions
Justice of the peace
g)
h)
Commissioner for oaths
Medical professional
A11. How to identify: How to verify:

Identify any beneficial owner connected with the customer Verify the identity of the natural persons who own or control more than 25% of the shares or
or service concerned. This information can be provided by voting rights or otherwise exercises control over the management of the legal person or
the customer (or on the customers behalf by the arrangement. The extent of this verification is dependent on the relevant risks.
customers duly authorised representative) or obtained This would be satisfied by verifying identity in line with the requirements for individuals.
from a reliable, independent source. This should include This could also be satisfied by one or more of the following alternative approaches in line
Designated Persons taking reasonable measures to with the risk policy of the Designated Person. In high risk scenarios a designated person
understand the ownership and control structure of the should use more than one source to verify information.
customer. This would comprise: a) obtaining a copy of the annual audited accounts listing shareholders, directors or
a) Any natural person who owns or controls more other persons exercising control over the customer (where the information is
than 25% of the shares or voting rights in the considered by the Designated Person to be current and reliable), or
legal person or arrangement; or b) for complex structures, (particularly where a company is registered abroad) a
b) ii) Any natural person who exerts ultimate relevant and up-to-date legal opinion from a source on which the Designated
control over the legal person through its Person is prepared to rely, documenting due diligence conducted, including in
management or otherwise. relation to information on the shareholding/control structure and directors (or
If, exceptionally, due to the nature or structure of the legal equivalent); or
person or arrangement, it is not feasible to identify any c) placing reliance on information provided/certified by counterparties/agents (e.g.
natural person who meets either of the definitions at i) or ii) in syndicated deals) where such persons are regulated credit or financial
above, the Designated Person may treat as exercising institutions or are legal or accountancy professionals subject to equivalent
control the directors (or equivalent) or other persons having AML/CTF obligations; or
the power to legally bind the customer. d) having a notary public (or equivalent) certify the validity of the information
The Designated Person must record the basis for their provided by or on behalf of the customer; or
decision in reaching the conclusions it has in relation to the e) placing reliance on information provided/certified by a Company Secretary (or
ownership/control of the customer. equivalent) - e.g. copies of constitutional documentation (e.g., Memo &
Articles/Certificates of Incorporation / Trust Deed) and shareholder certification.
In line with the Designated Persons Risk assessment the process may include verifying a
beneficial owners personal identity (the extent of verification required will depend on the
risk) in line with the requirements for personal customers. Such verification should be
considered the norm for any customer regarded by the designated person as higher risk.
A12. Specified Customers

Credit and Financial Institutions
Listed Companies
Public Bodies
Beneficial Owners of Pooled Accounts held by Solicitors and other Legal Professionals
Specified Products:
Electronic money
(If the device cannot be recharged, the maximum amount stored in the device is no more than EUR250 or EUR500, if the device cannot be
used outside the State. Where the device can be recharged, a limit of EUR2,500 is imposed on the total amount transacted in a calendar
year, except where an amount EUR1,000 or more is redeemed in that same calendar year by the bearer of electronic money).
Life assurance policy (having an annual premium of no more than EUR1,000 or a single premium of no more than EUR2,500)
Pensions
A13. In respect of:

a) a correspondent banking relationship; and
.
b) a business relationship or transaction with a non- resident PEP.
c) awithout
contained in this publication higher risk customer
obtaining (including
specific professional non
advice. The face to face)
application and impact of laws can vary widely based on the specific facts involved. No representation or warranty (express

2009 PricewaterhouseCoopers. are additional
All rights reserved. due diligencerefers
PricewaterhouseCoopers required for Politically
to the network Exposed
of member
firms of Persons (PEPs)?

A14. The Act requires designated persons to apply enhanced measures to PEPs that are resident outside the State but not to PEPs resident in
the State (under the definition of a PEP, an individual ceases to be so regarded one year after he has left office).
A15. Sec. 38(1) of the Act states that:

Prior to commencing the relationship, the credit institution
a) has gathered sufficient information about the respondent institution to understand fully the nature of the business of that
institution,
b) is satisfied on reasonable grounds, based on publicly available information, that the reputation of the respondent institution, and
the quality of supervision or monitoring of the operation of that institution in the place, are sound,
c) is satisfied on reasonable grounds, having assessed the anti-money laundering and anti-terrorist financing controls applied by the
respondent institution, that those controls are sound,
A13. a) a correspondent banking relationship; and
b) a business relationship or transaction with a non- resident PEP.
c) a higher risk customer (including non face to face)

In what circumstances are additional due diligence required for Politically Exposed Persons (PEPs)?
Q14.
Know
A14.
The Act requires designated persons to apply enhanced measures to PEPs that are resident outside the State but not to PEPs resident in
the State (under the definition of a PEP, an individual ceases to be so regarded one year after he has left office).
A15. Sec. 38(1) of the Act states that:

Prior to commencing the relationship, the credit institution
a) has gathered sufficient information about the respondent institution to understand fully the nature of the business of that
institution,
b) is satisfied on reasonable grounds, based on publicly available information, that the reputation of the respondent institution, and
the quality of supervision or monitoring of the operation of that institution in the place, are sound,
c) is satisfied on reasonable grounds, having assessed the anti-money laundering and anti-terrorist financing controls applied by the
respondent institution, that those controls are sound,
d) has ensured that approval is obtained from the senior management of the credit institution,
e) has documented the responsibilities of each institution in applying anti-money laundering and anti-terrorist financing controls to
customers in the conduct of the correspondent banking relationship.
A16. Yes - under Section 59 of the Act.
A17. Section 33(4) of the Act contains a supplementary obligation on a designated person where a customer who is an individual does not
present in person. This is not an alternative obligation but a supplementary one. The subsection provides that, without prejudice to the
generality of section 33(2)(a) of the Act, one or more of the following measures shall be applied by a designated person under section 33(1)
of the Act, where a customer who is an individual does not present to the designated person for verification in person of the customers
identity. e.g. verification of the identity with additional documentation; robust anti-fraud checks, etc.
Reporting
A18. An Garda Sochna Revenue Commissioners
Detective Superintendent, Suspicious Transactions Reports Office

Financial Intelligence Unit (FIU), Block D,
Garda Bureau of Fraud Investigation, Ashtowngate,
Harcourt Square, Navan Road,
Dublin 2 Dublin 15
Phone No: 01-6663714 Phone No: 01-8277542

Fax No: 01-6663711 Fax No: 01-8277484

.
Q20. Are there
or assume obligations to reportoranything
liability, responsibility duty of caremore
for anythan suspicious
consequences of youtransactions e.g. unusual
or anyone else acting, transactions,
or refraining cash
to act, in reliance transactions
on the abovein athis
information contained certain
threshold, based on it.
international wire transfers, other transactions etc.?
Yes - The Act requires that knowledge or suspicion or the reasonable grounds for suspicion that another person has been or is engaged in

A20. an offence of money laundering or terrorist financing shall be reported to the Garda Sochna and the Revenue Commissioners.
The Act requires in Sec. 43 to report any service or transaction which is connected with a place that does not have adequate procedures in
place for the detection of money laundering or terrorist financing (designated place under Sec.32).
A21. No.
Know
A19.
Information on the volume of SARs is not publicly available.
A20. Yes - The Act requires that knowledge or suspicion or the reasonable grounds for suspicion that another person has been or is engaged in
an offence of money laundering or terrorist financing shall be reported to the Garda Sochna and the Revenue Commissioners.
The Act requires in Sec. 43 to report any service or transaction which is connected with a place that does not have adequate procedures in
place for the detection of money laundering or terrorist financing (designated place under Sec.32).
A21. No.
A22. Yes - Sec. 43(2) provides that:

Except as provided by section 46, a person who fails to comply with this section commits an offence and is liable
a) on summary conviction, to a fine not exceeding EUR5,000 or imprisonment for a term not exceeding 12 months (or both), or
b) on conviction on indictment, to a fine or imprisonment for a term not exceeding 5 years (or both).
A23. No.
A24. According to Sec. 42 (7) A designated person who is required to make a report under this section shall not proceed with any suspicious
transaction or service connected with the report, or with a transaction or service the subject of the report, prior to the sending of the report to
the Garda Sochna and the Revenue Commissioners unless
a) it is not practicable to delay or stop the transaction or service from proceeding, or
b) the designated person is of the reasonable opinion that failure to proceed with the transaction or service may result in the other
person suspecting that a report may be (or may have been) made or that an investigation may be commenced or in the course of
being conducted.
Nothing in subsection (7) authorises a designated person to proceed with a service or transaction if the person has been directed or ordered
not to proceed with the service or transaction under section 17 and the direction or order is in force.
A25. No.
.
refers to
who are committed to delivering the network
quality of member
in assurance,
firms
tax and of
advisory

Hungary
Key contact: Paul Grocott Postal address: Last updated:
Email: paul.grocott@hu.pwc.com Wesselnyi utca 16.; H-1077 Budapest; January 2013
Tel: +36 1 461-9260 Hungary
General
A1. The AML Act Act CXXXVI of 2007 on the Prevention and Combating of Money Laundering and Terrorist Financing came into effect on 14
December 2007 and is still currently in force.
A2. N/A
A3. a) Hungarian Financial Supervisory Authority - http://www.pszaf.hu/en/

b) Hungarian Financial Supervisory Authority, plus Hungarian National Bank - http://www.pszaf.hu/en/
c) casinos: national tax authority (National Tax and Customs Administration) - http://en.apeh.hu/
d) other:
a. for auditors: Chamber of Hungarian Auditors - http://www.mkvk.hu/
b. for attorneys, law firms, notaries, etc local Bar which they are the member of
c. for trading companies: chambers they belong to
d. tax advisors and advisors dealing with real estate issues: FIU - http://nav.gov.hu/nav/penzmosas/peii
A4. Yes, each regulator, indicated above in A3, issued guidance and/or template AML documents.
A5. Yes - in cases where there are doubts surrounding the verification or adequacy of the customer identification data obtained previously.
A6. Yes - simplified and enhanced customer due diligence.
A7. No information available on this publicly.
.
2013 PwC.
accept reserved.
assumeNot
consequences refers
context requires,
on it.
network
exercise of member
of another firms of
member

A6. Yes - simplified and enhanced customer due diligence.
Questions
Q7. Has and been
Know
A7.
No information available on this publicly.
.
This publicationIfhas been
Yes, prepared
what arefor
the general
variousguidance on mattersinofplace?
thresholds interest for the personal use of the reader, and does not constitute professional advice. You should not act upon the information
agents do not accept
Yes -orone-off
assume any liability, responsibility
transactions or duty of care for
below EUR15,000 any consequences
(HUF3.6m) (otherof you
than or anyone
whereelse acting,
there areortwo
refraining to act,such
or more in reliance on the information
transactions which contained
the firmin this
believes
A8.
are linked, and which together would amount to EUR15,000 or more) or any amount which is viewed to be of a suspicious nature.
A9. For the purposes of identification and verification procedures, service providers require the following documents to be presented:
Natural persons:
a) personal identification document (official identity card) and official address card of Hungarian citizens; and
b) passport or personal identity card for foreign nationals or documentary evidence of the right of residence or a valid residence
permit.
Legal persons and business associations:

a) the application for registration or the document of registration for recognised legal persons, or the articles of incorporation of legal
persons and business associations lacking legal status whilst not yet registered by the registrar of companies, court or appropriate
authority; and
b) for non-resident legal persons and business associations lacking the legal status of a legal person, the document proving that the
person or body has been registered under the law of the country in which it is established.
A10. Certified copies of the documents shall be accepted for identification procedures if certified by the competent authority of the country where
it was issued or by the competent Hungarian foreign representative.
Certified copies of the documents referred to above shall be accepted for the verification of the identity of the customer if:
a) it was prepared by the officer of a Hungarian consular post or by a notary public, and certified accordingly; or
b) the officer of a Hungarian consular post or the notary public has provided an endorsement for the copy to verify that the copy is
identical to the original presented; or
c) the copy was prepared by an authority of the country where it was issued, if such authority is empowered to make certified copies
and the competent Hungarian consulate officer has provided a confirmatory certification of the signature and seal of the authority.
A11. Beneficial owner is defined as:

a) the natural person who owns or controls at least 25% of the shares or voting rights in a legal person or business association
lacking the legal status of a legal person, if that legal person or business association lacking the legal status of a legal person is
not listed on a regulated market and is subject to disclosure requirements consistent with European Community legislation or
subject to equivalent international standards;
b) the natural person who has a dominant influence on a legal person or business association lacking the legal status of a legal
person; and
c) the natural person on whose behalf a transaction is carried out.
When establishing a business relationship, the customer acting on behalf of the beneficial owner shall indicate in a written statement the
details of the beneficial owner such as surname, forename, address and nationality. The service provider may request the customer to
supply other details of the beneficial owner (e.g. number/type of identification document, place of residence in Hungary for foreign nationals,
date of birth and mother's name) to prevent and combat money laundering and terrorist financing. Where there is any doubt concerning the
identity of the beneficial owner, the service provider must take measures to check the beneficial owners' identification data in publicly
available records and registers.
.
b) the natural person who has a dominant influence on a legal person or business association lacking the legal status of a legal
person; and
c) the natural person on whose behalf a transaction is carried out.
When establishing a business relationship, the customer acting on behalf of the beneficial owner shall indicate in a written statement the
Questions
details ofand Answers:
the beneficial owner such as surname, forename, address and nationality. The service provider may request the customer to

supply other details of the beneficial owner (e.g. number/type of identification document, place of residence in Hungary for foreign nationals,
date of birth and mother's name) to prevent and combat money laundering and terrorist financing. Where there is any doubt concerning the
identity of the beneficial owner, the service provider must take measures to check the beneficial owners' identification data in publicly
available records and registers.
A12. Simplified Customer Due Diligence applies where the customer is:
a) a service provider engaged in carrying out the activities defined in the law (financial services, investment services, insurance
services, commodity exchange, postal financial intermediation services and voluntary mutual insurance fund services) in the
territory of the European Union ('EU'), or a service provider that is engaged in these activities and situated in a third country which
imposes requirements equivalent to those laid down in the Money Laundering Act;
b) a listed company whose securities are traded on a regulated market in one or more member states, or a listed company from a
third country that is subject to disclosure requirements consistent with European Community legislation; and
c) a supervisory body mentioned in the law/central government body or a local authority/a body of the European Community.
.
This publicationSimplified Customer
has been prepared Dueguidance
for general Diligence also applies
on matters of interestfor: insurance
for the personal use policies withand
of the reader, a low-level annual/single
does not constitute premium/insurance
professional policies
advice. You should not act upon thefor pension
information
schemes
contained in this publicationifwithout
thereobtaining
is no surrender clauseadvice.
specific professional and where the funds
The application payable
and impact to can
of laws thevary
insured person
widely based cannot
on the be
specific used
facts as collateral
involved. for any
No representation credit or
or warranty (express
loanasarrangement.
to the accuracy orAn completeness
insurance of company
the information contained
shall not be in this publication,
required and, to the
to apply extent permitted
customer by law, PricewaterhouseCoopers
due diligence LLP, its members,
measures for identifying employees
a customer whoseand
identity
publication or for has already
any decision based on it.been established by an independent insurance intermediary for the same purpose.

a) customers that have not been physically present for identification purposes or the verification of their identity;
b) correspondent banking relationships;
c) Politically Exposed Persons ('PEPs'); and
d) transactions for the exchange of money involving a sum of EUR2,000 or more (HUF500,000 or more).
The service provider will record further information pertaining to the business relationship and the transaction order e.g. the type, subject
matter and term of the contract of the business relationship and the subject matter and the value of the transaction order.
A14. Customers residing in another member state or in a third country are required to provide a statement as to whether they are considered
politically exposed according to national law of their country. In respect of transactions or business relationships with PEPs residing in
another member state or in a third country, approval from the management body, as defined in the organisational and operational
regulations, is required.
A15. Service providers engaged in the provision of financial services or in activities auxiliary to financial services are required, before establishing
correspondent banking relationships with respondent institutions from third countries, to:
a) assess, evaluate and analyse the respondent service providers anti-money laundering and anti-terrorist financing controls;
b) be satisfied that the respondent service provider has verified the identity of and performed ongoing due diligence on the
customers having direct access to accounts of the correspondent and that it is able to monitor access to the accounts of the
correspondent on an ongoing basis; and
c) be satisfied that the respondent service provider is able to provide relevant customer due diligence data to the correspondent
institution, upon request.
Approval from the management body must be obtained to engage in correspondent banking relationships.
A16. Yes - service providers engaged in financial services activity or in activities auxiliary to financial services are prohibited to engage in or
continue a correspondent banking relationship with a shell bank or with a service provider that is known to permit its accounts to be used by
a shell bank.
approach and procedures they have adopted. Service providers are required to record all data and particulars specified in the law, where
the customer has not been physically present for identification purposes or for the verification of his identity.
.
Know
Reporting
Q18. by country comparison of high level Know Your Customer and Anti-Money Laundering information
Country
A18. FIU (Financial Intelligence Unit) which is currently the Hungarian Customs and Finance Guard within the National Tax and Customs
Authorisation.
Reporting
http://nav.gov.hu/nav/penzmosas/peii
A18. FIU (Financial Intelligence Unit) which is currently the Hungarian Customs and Finance Guard within the National Tax and Customs
Authorisation.
http://nav.gov.hu/nav/penzmosas/peii
2011 6,178 SARs

*
2011
Whatwas
USD140.0 billion
the volume of (Source:
SARs made to the authorities)in the most recent year? Please state the GDP for the equivalent year.
data.worldbank.org
Q19.
2011
Are 6,178
there SARs
2011 USD140.0 billion (Source: data.worldbank.org* )
A20. No.
Q21. Are there any
threshold, de-minimiswire
international thresholds below
transfers, otherwhich transactions
transactions etc.? do not need to be reported?
A21. No.
A20. No.
A22. Yes - Up to 2 years imprisonment for non-reporting.

A21. No.
A23. No.
A22. Yes - Up to 2 years imprisonment for non-reporting.
Q24. Is there
Are a requirement
there to obtain
any requirements authority
(legal to proceed
or regulatory) withautomated
to use a current/ongoing transaction
Suspicious thatmonitoring
Transaction is identifiedtechnology?
as suspicious?
Q23.
A24. Work needs to be ceased at reporting. Written information is required from the FIU in order to continue.
A23. No.
A25. No.
Work needs to be ceased at reporting. Written information is required from the FIU in order to continue.
A24.
A25. No.
.
publication prices isbased
or for any decision the sum
on of
it. gross value added by all resident producers in the economy plus any product taxes and minus any subsidies not included in the value of the products. It is
domestic
currencies using single year
alternative conversion factor
reserved.
official exchange
is used. Limited, each
rates. For a few countriesrefers
wheretothetheofficial
network
of which is a separate and independent legal entity.
of member
exchange ratefirms

doesofnot reflect the rate effectively applied to actual foreign exchange transactions, an
.
www.pwc.com.
This publication
in this guidance
publication, on to
LLP, its You should
members, not act
employees upon
and
the information
agents do not accept or assume any liability, responsibility contained
or duty of care in
forthis
anypublication
consequences without obtaining
of you specific
or anyone else professional advice.to
acting, or refraining Noact,
representation
in reliance onorthe
warranty (express
information or implied)
contained in thisis given as
Guernsey
Guernsey
Key contact: Nick Vermeulen Postal address: Last updated:
Key contact: Nick Vermeulen Postal address:
RBS Place, 1 Glategny Esplanade; Last updated:
Email: nick.vermeulen@gg.pwc.com January 2013
Email: nick.vermeulen@gg.pwc.com RBS Place, 1 ;Glategny
St.Peter Port Esplanade;
Guernsey, GY1 4ND January 2013
Tel: +44 (0) 1481 752089
Tel: +44 (0) 1481 752089 St.Peter Port ; Guernsey, GY1 4ND
General
General
A1. The Criminal Justice (Proceeds of Crime) (Bailiwick of Guernsey) Law was issued in 1999. It is supplemented by the Criminal Justice
A1. The Criminal
(Proceeds ofJustice
Crime) (Proceeds of Crime)Businesses)
(Financial Services (Bailiwick of (Bailiwick
Guernsey)ofLaw was issued
Guernsey) in 1999. It
Regulations, is supplemented
2007 by theand
('the Regulations') Criminal Justice for
the Handbook
(Proceeds of Crime)Businesses
Financial Services (Financial Services Businesses)
on Countering (Bailiwick
Financial Crime andof Guernsey) Regulations,
Terrorist Financing ('the2007 ('the Regulations') and the Handbook for
Handbook').
Financial Services Businesses on Countering Financial Crime and Terrorist Financing ('the Handbook').
A2. AML legislation requiring customer due diligence procedures was introduced in 2002. The 2007 Regulations and Handbook represent an
A2. AML legislation
update requiring
to the 2002 customer due diligence procedures was introduced in 2002. The 2007 Regulations and Handbook represent an
requirements.
update to the 2002 requirements.
Q3. Who
etc.).isPlease
the regulator
includefor
linkAML controls
to the for: (a)website.
regulator(s) Banking; (b) Other financial Services; (c) Non financial sector (e.g. casinos, high value goods
A3. Guernsey Financial Services Commission (www.gfsc.gg)

A3. Guernsey Financial Services Commission (www.gfsc.gg)
Q4. Is there
local any practical
legislation? guidance
Please provided
include to firms where
link to website, by public authorities regarding AML requirements, beyond the FATF recommendations and
available.
A4. Yes - The AML Handbook has specific guidance for industries on the application of AML requirements. For example, the AML Handbook for
A4. Yes - The AML Handbook
the accountancy sector. has specific guidance for industries on the application of AML requirements. For example, the AML Handbook for
the accountancy sector.
A5. No however verification procedures are required for such customers at appropriate times on a risk sensitive basis.
A5. No however verification procedures are required for such customers at appropriate times on a risk sensitive basis.

A6. Yes - the Regulations and Handbook became effective on 15 December 2007 for regulated financial services businesses. The regulations
A6. Yes
were- the Regulations
extended and Handbook
in September became
2008 and effective
October 2010 tooncover
15 December 2007 for
certain services regulated
offered financialaccountants
by lawyers, services businesses.
and estateThe regulations
agents.
were extended in September 2008 and October 2010 to cover certain services offered by lawyers, accountants and estate agents.
Q7. Has thefind
please country
a linkbeen
to a the subject
relevant of a (if
report FATF (or FATF-style)
publicly available). Mutual Evaluation or IMF assessment exercise in the last three years? If yes,
A7. Yes IMF Assessment in January 2011. Available on IMF website.

A7. Yes IMF Assessment in January 2011. Available on IMF website.

Q8. Are there
If Yes, minimum
what are thetransaction thresholds,
various thresholds under which customer due diligence is not required?
in place?
.
. This publication has been prepared for general guidance on matters of interest for the personal use of the reader, and does not constitute professional advice. You should not act upon the information
contained
This in thishas
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A6. Yes - the Regulations and Handbook became effective on 15 December 2007 for regulated financial services businesses. The regulations
were extended in September 2008 and October 2010 to cover certain services offered by lawyers, accountants and estate agents.
Questions
Q7. Has the and
country Answers:
been the subject of a FATF (or FATF-style) Mutual Evaluation or IMF assessment exercise in the last three years? If yes,
Know
A7.
Yes IMF Assessment in January 2011. Available on IMF website.
.
A8.
This publicationYes
has one-off
been transactions
prepared (single
for general guidance on or linked)
matters under
of interest forGBP10,000
the personal usedo notreader,
of the requireandcustomer due diligence.
does not constitute professional advice. You should not act upon the information
A9. Individuals: name, address, date of birth, nationality, occupation, official personal identification number. No specific documents are
mandatory, but local guidance dictates that evidence of identity should be obtained from documents issued by reputable sources, for
example a passport or other national identity card. Separate verification of other details is also required.
Legal Entities: Specific requirements vary depending on the risk profile of the applicant for business. Minimum evidence expected is one
of:
a) original or certified copy of the certificate of incorporation and memorandum and Articles of Association;
b) company registry search;
c) latest audited financial statements;
d) a copy of the Directors' Register;
e) a copy of the shareholders' register;
f) independent information sources, including electronic sources; or
g) a personal visit to the principle place of business.
In addition, identification and verification must be completed for individuals ultimately owning 25% or more of the legal entity and individuals
(including directors and beneficial owners) with ultimate effective control over the assets of the legal entity.
A10. Where non face- to-face identification and verification is carried out, a certified copy of the identification documentation is required (by a
Notary Public or other qualified professional able to legally certify documents).
A11. Beneficial owners and controllers must be identified and verification documentation obtained, including, at a minimum, those holding 25% or
more interest in the capital of the entity.
A12. Reduced and simplified arrangements are available for identification and verification procedures of regulated institutions and publically
traded companies. There is also some scope for reliance to be placed on procedures already conducted by intermediary regulated
institutions.
Politically Exposed Persons (PEPs) risk, client not physically present for identification purposes, correspondent banking relationships,
A14. Additional due diligence and enhanced scrutiny is required on all accounts that have links with PEPs, but particularly those with links to
countries that are vulnerable to corruption.
.
Politically Exposed Persons (PEPs) risk, client not physically present for identification purposes, correspondent banking relationships,

A14. Additional due diligence and enhanced scrutiny is required on all accounts that have links with PEPs, but particularly those with links to
countries
Country by countrythatcomparison
are vulnerable to
ofcorruption.
high level Know Your Customer and Anti-Money Laundering information
A15. Local requirements specifically identify correspondent banking relationships as a trigger for enhanced measures. Specific measures
required include:
a) gathering sufficient information to understand the nature of the respondent's business;
b) determining the reputation of the institution from publically available information;
c) assessing the respondent institution's AML policies;
d) obtaining senior management approval for taking on the client; and
e) documenting the respective AML responsibilities of each institution.
.
agents do not accept with shell
or assume any liability, banksorspecifically
responsibility prohibited?
duty of care for any consequences of you or anyone else acting, or refraining to act, in reliance on the information contained in this
A16. Yes.
A17. Additional measures are required for non face-to-face transactions and/or relationships. Examples of such measures are:
a) additional verification documentation;
b) development of independent contact with the client;
c) third party introduction; and
d) requiring the first payment to be carried out through a bank account situated in an equivalent jurisdiction.
Reporting
A18. GFIS Guernsey Financial Intelligence Service as a division of the Guernsey Financial Investigation Unit. (www.guernseyfiu.gov.gg)

2011 1,136 SARs
GDP data is only available for the Channel Islands as a whole.
A20. Whilst there is no specific legal requirement, there is guidance for specific industries (for example, high value goods dealers) on unusual
A21. No.
A22. Yes there are penalties for Failure to report, Assisting and Tipping Off.
.
A20. Whilst there is no specific legal requirement, there is guidance for specific industries (for example, high value goods dealers) on unusual

Know
No.
Country
A22. Yes there are penalties for Failure to report, Assisting and Tipping Off.
A23. No.
.
Q24. Is there
or implied) is given a requirement
as to the to obtainofauthority
accuracy or completeness to proceed
the information with
contained in a current/ongoing
this publication, transaction
and, to the extent permitted that isPricewaterhouseCoopers
by law, identified as suspicious?LLP, its members, employees and
A24. Yes authorisation is required to proceed if transactions are identified as suspicious.
A25. No.
www.pwc.com.
.
Greece
Key contact: Emil Yiannopoulos Postal address: Last updated:
Email: emil.yiannopoulos@gr.pwc.com 268 Kifissias Avenue, GR-152 32 Athens, January 2013
Tel: +30 210 6874 640 Greece
General
A1. 1995 (amended 2005, 2006 and 2008).
A2. N/A.
A3. The Regulators for the AML controls are the public authorities ("Competent Authorities") which supervise the compliance of obliged persons
with the provisions of the Greek AML legislation.
The Competent Authorities are:

a) the Bank of Greece for: credit institutions; leasing companies; factoring companies; bureaux de change; intermediaries in funds
transfers; credit companies; and postal companies, only to the extent that they act as intermediaries in funds transfers. The Bank
of Greece, in supervising these companies cooperates with the Ministry of Transport and Communications and the National
Telecommunications and Post Commission; insurance companies; insurance intermediaries.
b) the Hellenic Capital Market Commission for: portfolio investment companies in the form of a societe anonyme; management
companies of mutual funds; management companies of mutual funds investing in real estate; management companies of mutual
funds for venture capital; investment firms and investment intermediary firms.
c) the Accounting and Auditing Supervisory Commission for chartered accountants and audit firms;
d) The Ministry of Economy and Finance (General Directorate of Tax Controls) for: venture capital firms; companies providing
business capital; tax consultants, tax experts and related firms; independent accountants and private auditors; real estate agents
and related firms; auction houses; dealers in high value goods; auctioneers; and pawnbrokers;
e) the Gambling Control Commission of law 3229/2004 (O.G.G. A 38) for: casino enterprises; casinos operating on ships flying the
Greek flag; companies, organisations and other entities engaged in gambling activities; and betting outlets;
f) the Ministry of Justice for notaries; lawyers;
g) the Ministry of Development for the natural or legal persons providing services to companies and trusts (trust and companies
service providers)
h) for branches in Greece of financial institutions which have their registered office abroad, the competent authority shall be the
corresponding authority responsible for domestic financial institutions conducting activities similar to those of such foreign
financial institutions.
A4. The Competent Authorities have issued Interpretative Circulars, Decisions and Regulatory Acts, each one giving instructions and
interpretations of the AML provision to the obligated persons under their supervision. The Competent Authorities through such
decisions/Acts have the power to modify the obligations laid down in the Greek AML legislation for the Obligated Persons.
A5. Greek AML legislation states that obligated persons may apply, at the appropriate time, risk-based due diligence measures not only to new
but also to existing customers. Decisions of the competent authorities may determine the criteria and the method of application of due
diligence to existing customers.
.
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A6. Yes.
A7. Yes -
http://www.fatf-gafi.org/countries/d-i/greece/documents/follow-upreporttothemutualevaluationreportofgreece.html
A8. Yes In principle, occasional (one-off) transactions below EUR15,000; a lower threshold of EUR1,000 per insurance contract per year (or of
EUR2,500 in the case of a one-off payment). The law also caters for a lower threshold option in relation to electronic funds transfers
depending on the decision and guidance provided by the respective regulatory authority.
A9. Individuals:
For identifying individuals, a police identity card or passport plus any other document that provides evidence of his/her residential and
business address, as well as his/her profession and tax registration number
Legal Entities:
Most recent legal documentation as defined by Greek law depending on the type of entity, identifying:
a) business name, address and purpose of the entity;
b) representation and signing authorities of the entity;
c) any changes and amendments on the statutes of the entity and/or its representatives;
d) police identity cards or passports of the legal representative(s) of the entity as well as evidence of their current residence;
e) Tax registration number; and,
f) Beneficial Owner(s).
Notwithstanding the above, and specifically for the Credit Institutions, the Bank of Greece Governors Act No. 2652/29.2.2012 determined
that the customers income shall be verified through the customers income tax clearance form or, in the case of legal persons, the income
tax returns filed (including confirmation of their filing that includes the tax payable), with the exception of the cases where the customer is
exempted from the obligation to file income tax returns in accordance with the relevant provisions of the Income Tax Code.
A10. Copies of identification documents may be certified by a state authority, a notary public or a lawyer. Copies may also be certified by an
authorised employee of a financial institution upon presentation of the originals.
A11. Beneficial owners are:

In the case of corporate entities:
a) the natural person(s) who ultimately own(s) or control(s) a legal entity through direct or indirect ownership or control over a
sufficient percentage of the shares or voting rights in that legal entity, including through bearer share holdings (other than a
company listed on a regulated market that is subject to disclosure requirements consistent with community legislation or subject to
equivalent international standards - a percentage of 25% plus one share shall be deemed sufficient to meet this criterion);
b) the natural person(s) who otherwise exercise(s) control over the management of a legal entity.
In the case of legal entities, such as foundations and legal arrangements, and trusts, which administer and distribute funds:
a) where the future beneficiaries have already been determined, the natural person(s) who is the beneficiary of 25% or more of the
property of a legal arrangement or entity;
b) where the individuals that benefit from the legal arrangement or entity have yet to be determined, the class of persons in whose
. main interest the legal arrangement or entity is set up or operates;
c) prepared for general
the natural guidancewho
person(s) on matters of interestcontrol
exercise(s) for the personal use of or
over 25% the more
reader,of
andthe
does not constitute
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legal arrangement not act upon the information
or entity.
Q12. In what circumstances are reduced/simplified due diligence

refers to the arrangements
network of memberavailable?
firms of

A12. Under local legislation it is up to the discretion of the relevant party to decide not to perform identity checks (unless there is a suspicion of
money laundering) for financial institutions or organisations (entities regulated by the Bank of Greece).
company listed on a regulated market that is subject to disclosure requirements consistent with community legislation or subject to
equivalent international standards - a percentage of 25% plus one share shall be deemed sufficient to meet this criterion);
b) the natural person(s) who otherwise exercise(s) control over the management of a legal entity.
In the case of legal entities, such as foundations and legal arrangements, and trusts, which administer and distribute funds:
Questionsa) and
whereAnswers:
the future beneficiaries have already been determined, the natural person(s) who is the beneficiary of 25% or more of the

property of a legal arrangement or entity;
b) where the individuals that benefit from the legal arrangement or entity have yet to be determined, the class of persons in whose
main interest the legal arrangement or entity is set up or operates;
c) the natural person(s) who exercise(s) control over 25% or more of the property of a legal arrangement or entity.
A12. Under local legislation it is up to the discretion of the relevant party to decide not to perform identity checks (unless there is a suspicion of
money laundering) for financial institutions or organisations (entities regulated by the Bank of Greece).
In addition, there are reduced due diligence requirements (no verification requirement) for other types of entities such as:
a) listed companies whose securities are admitted to trading on a regulated market in one or more Member States and listed
companies from other countries which are subject to disclosure requirements consistent with Community legislation;
b) beneficial owners of pooled accounts held by notaries and other independent legal professionals from the Member States, or from
other countries provided that they are subject to requirements to combat money laundering or terrorist financing consistent with
international standards and are supervised for compliance with those requirements and provided that the information on the
identity of the beneficial owner is available, on request, to the institutions that act as depository institutions for the pooled
accounts;
c) companies operating as undertakings for collective investment in transferable securities and companies that operate as
undertakings for collective investment in transferable securities, are based in the European Union and operate in consistency with
the provisions of Directive 85/611/EEC as currently in force;
d) public law legal entities and state owned organisations of at least 51%; and
e) public authorities which satisfy certain requirements.
Moreover there are reduced due diligence requirements (no verification requirement) for:
a) life insurance policies where the annual premium is no more than EUR 1,000 or the single premium is no more than EUR2,500;
b) a pension, superannuation or similar scheme that provides retirement benefits to employees, where contributions are made by
way of deduction from wages and the scheme rules do not permit the assignment of a member's interest under the scheme;
c) insurance policies for pension schemes if there is no surrender clause and the policy cannot be used as collateral; and
d) electronic money, where the maximum amount stored in the device is no more than EUR250, or where, if the device can be
recharged, a limit of EUR2,500 is imposed on the total amount transacted in a calendar year, except when an amount of
EUR1,000 or more is redeemed in that same calendar year by the bearer.
A13. On a risk-sensitive basis, enhanced customer due diligence measures are required, especially for:
a) transactions without the physical presence of the customer;
b) cross border correspondent banking; and
c) politically exposed persons.
Moreover, most of the Competent Authorities have issued guidance that the following type of customers should be considered as high risk
for money laundering purposes and should be subjected to enhanced due diligence procedures:
a) companies with bearer shares;
b) offshore companies;
c) non-profit entities or organisations;
d) persons from countries that do not adequately implement FATF recommendations; and
e) trust or similar Foreign Law Entities.
f) Non-residents accounts
g) Portfolio management accounts of important clients
h) Business relationships and transactions that entail high risks related to tax evasion (this high risk category shall at least include: (i)
Self-employed persons whose total income credited on their own accounts or on accounts of which they are the beneficial owners
exceed EUR200,000 during the previous calendar year (ii) Legal persons whose total cash deposits or cash withdrawals exceed
EUR300,000 during the previous calendar year).
.
A14. Where
or implied) is given as tothe PEP isornot
the accuracy a Greek of
completeness resident.
the information contained in this publication, and, to the extent permitted by law, PricewaterhouseCoopers LLP, its members, employees and
What enhanced due diligence must be performed for correspondent banking relationships (cross-border banking and similar relationships)?

Q15.
A15. In respect of cross-frontier correspondent banking relationships with respondent institutions from third countries, credit institutions shall:
a) gather sufficient information about a respondent institution to understand fully the nature of the respondent's business and to
determine from publicly available information the reputation of the institution and the quality of supervision;
b) assess the respondent institution's anti-money laundering and anti-terrorist financing controls;
c) obtain approval from senior management before establishing new correspondent banking relationships;
e) with respect to payable-through accounts, be satisfied that the respondent credit institution has verified the identity of and
performed ongoing due diligence on the customers having direct access to accounts of the correspondent and that it is able to
provide relevant customer due diligence data to the correspondent institution.
A16. Yes.
e) with respect to payable-through accounts, be satisfied that the respondent credit institution has verified the identity of and
performed ongoing due diligence on the customers having direct access to accounts of the correspondent and that it is able to
provide relevant customer due diligence data to the correspondent institution.

Know
Yes.
Country
A17. Additional due diligence is required to mitigate the higher risk profile associated with non face-to-face transactions. Where a customer
approaches a firm remotely (by post, telephone or over the internet), the firm should have appropriate procedures to carry out non face-to-
face verification, either electronically or by reference to documents, by having in place additional verification checks to manage the risk of
identity fraud.
In this respect, obligated persons should take specific and adequate measures to counter the higher risk in cases where the customer is not
physically present for identification purposes, mainly by applying one or more of the following measures:
a) ensuring that the customers identity is verified by additional documents, data or information;
b) taking supplementary measures to verify or certify the documents supplied, or requiring confirmatory certification by a credit or
financial institution based in the European Union; and
c) ensuring that the first payment of the operations is carried out through an account opened in the customers name with a credit
institution based in the European Union.
Obligated persons should pay special attention to any product or transaction which might favour anonymity and which, by nature or by virtue
of information about the profile of the characteristic features of the customer, may be associated with money laundering or terrorist financing
and take appropriate measures to avert this risk.
Reporting
A18. Greek F.I.U. (Anti-Money Laundering, Counter Terrorist Financing and Source of Funds Investigation Authority) http://www.hellenic-
fiu.gr/index.php?lang=en.

1 September 2008 to 30 April 2009 1,708 (Greek FIU)
. There are Competent Authorities who have issued instructions to the obligated persons under their supervision for reporting, apart from
A20.
suspicious transactions for money laundering andapplication
terroristand
financing, criminal activities (predicate offences, especially those connected with
contained in this publication without obtaining specific professional advice. The impact of laws can vary widely based on the specific facts involved. No representation or warranty (express
tax evasion)
or implied) is given as well
as to the accuracy as unusualoftransactions/activities.
or completeness the information contained in this publication, and, to the extent permitted by law, PricewaterhouseCoopers LLP, its members, employees and
Moreover, the Compliance Officers of certain Obliged Persons (including credit and financial institutions) are required to prepare a report, on
an annual/bi-annual basis, providing considerable input for the assessment of the obliged persons compliance with the AML/CF provisions /
policy. Such reports are assessed by the obliged persons management (e.g. Board of Directors) and are submitted to the relevant

Competent Authority in electronic form or in a hard copy.
In addition relevant obliged persons (Payment Institutions and Electronic Money Institutions which have obtained license for establishment
and operation in Greece as well as foreign Payment Institutions and Electronic Money Institutions which provide payment services (carry
out transfer of funds) through established Greek branches or agents) are required to submit to the Competent Authority (Bank of Greece) on
a semi-annual basis, data for the total number and amount of cross border transfer of funds from and to abroad (inbound and outbound
funds), per country of payers establishment (for inbound funds) or beneficiarys (for outbound funds).
A21. No.
A22. An employee of an obligated legal entity or any other person obliged to report suspicious transactions shall be penalised with a term of
imprisonment up to 2 years if he intentionally fails to report to the competent authorities suspicious or unusual transactions or activities or
provides false or misleading data, in breach of the relevant legal, administrative or regulatory provisions and rules, provided that his act is
not punishable with heavier criminal sanctions.
Furthermore, the Competent Authorities have the power to impose on the obligated legal person a wide range of administrative sanctions if
they fail to comply with their obligations under Greek AML legislation.
and operation in Greece as well as foreign Payment Institutions and Electronic Money Institutions which provide payment services (carry
out transfer of funds) through established Greek branches or agents) are required to submit to the Competent Authority (Bank of Greece) on
a semi-annual basis, data for the total number and amount of cross border transfer of funds from and to abroad (inbound and outbound
funds), per country of payers establishment (for inbound funds) or beneficiarys (for outbound funds).

Know
No.
Country
A22. An employee of an obligated legal entity or any other person obliged to report suspicious transactions shall be penalised with a term of
imprisonment up to 2 years if he intentionally fails to report to the competent authorities suspicious or unusual transactions or activities or
provides false or misleading data, in breach of the relevant legal, administrative or regulatory provisions and rules, provided that his act is
not punishable with heavier criminal sanctions.
Furthermore, the Competent Authorities have the power to impose on the obligated legal person a wide range of administrative sanctions if
they fail to comply with their obligations under Greek AML legislation.
A23. According to a Bank of Greece Governors Act, Credit Institutions (and to some extent Financial Institutions) have the obligation to install
adequate IT systems and effective procedures for continuously monitoring accounts and transactions, in order to detect, monitor and assess
high-risk transactions and customers. IT systems should be capable of providing timely, reliable and necessary information for detecting,
analysing and effectively monitoring customers accounts and transactions. Accounts and transactions should be monitored in relation to the
typology of transactions, the customers profile, and the anticipated operation of the account in relation to the operation of other accounts in
the same customer category. IT systems should be used for obtaining information on defective customer identification, the customers
profile and overall data on the Credit Institutions business relationship with the customer.
A24. The obligated persons must refrain from carrying out transactions, engaging in activities or providing any services, which they know or
suspect to be related to money laundering and terrorist financing offences, unless refraining in such manner is impossible or likely to
frustrate efforts to pursue the customers, the beneficial owners or the persons on behalf of whom the customers may be acting; in the latter
case the obligated persons shall execute the aforementioned operations and simultaneously inform the Greek F.I.U.
A25. Law provides that: Money laundering shall be regarded as such even where the activities which generated the property to be laundered
were carried out in the territory of another country, provided that would be a predicate offence if committed in Greece and are punishable
according to the law of such other country.
Furthermore the Greek F.I.U. have the power to request the obligated persons to provide all information required for the performance of
their duties, including grouped information about certain categories of transactions or activities of domestic or foreign natural or legal
persons or entities.
.
www.pwc.com.
Gibraltar
Key contact: Ivan P Perez Postal address: Last updated:
Email: ivan.p.perez@gi.pwc.com International Commercial Centre; January 2013
Tel: +350 78267 Ext 122 Casemates Square; Gibraltar
General
A1. 1996 (amended in 2005 and 2007).
A2. N/A.
A3. The Gibraltar Financial Services Commission (FSC) - http://www.fsc.gi .
A4. Yes, the Anti-Money Laundering and Terrorist Financing Guidance Notes - http://www.fsc.gi/amlgn/ .
A5. Yes - only for clients of Banks and Fiduciary service providers licensed by the FSC.
A6. Yes - amendments introduced and applicable from 15 December 2007.
A7. No.
A8. Yes - one-off transactions below EUR15,000.
.
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A9. Individuals:
Physical identity (e.g. name, date of birth, registration number), address and the source of their income/wealth. Passports or identity cards
should be used for verification of physical identity and utility bills or alternatives, such as checking the electoral register/telephone directory,
should be used for verification of address.
Companies:
Copy of the latest report and accounts, board resolution to open the relationship and the empowering authority for those who will operate
any account and certificate of incorporation/certificate of trade or equivalent. Also required are authorised signatories for the
account/transaction, holders of powers of attorney to operate the account/transaction as well as ultimate beneficial owners (UBO) and
shareholders if different from the UBO.
A10. Where verification of identity is required, the documents should be independently verified by the institution itself. High risk customers should
have their identification, address and source of income/wealth verified using at least two independent sources other than the document in
question. Certified documents must be signed and dated by an external third party, such as a notary, lawyer, accountant etc.
A11. It is considered appropriate to verify the identity of beneficial owners holding 25% or more. Where a principal owner is another corporate
entity or trust, the firm should take measures to look behind that entity and establish the identities of its beneficial owners or trustees, unless
that company is publicly quoted. The firm will then judge which of the beneficial owners exercise effective control, and whose identities
should therefore be verified.
A12. The level of documentation required should be adapted according to the risk profile of the customer, the level and nature of the business,
the risk tolerance of the institution and any existing relationships with that customer. Local guidance requires that institutions have a
methodology which classifies the different types of customers into risk categories and processes that adequately mitigate the risks posed by
these.
A13. Where an entity is known to be linked to a Politically Exposed Person ('PEP'), or to a jurisdiction assessed as carrying a higher money
laundering/terrorist financing risk, or where the company is engaged in activities that are assessed to carry a higher money laundering risk,
further verification and/or monitoring may be required.
A14. The systems of control that firms must adopt to reduce the risks associated with establishing and maintaining business relationships with
PEPs include:
a) establishing and documenting a clear policy and internal guidelines, procedures and controls regarding such business
relationships;
b) maintaining an appropriate risk management system to determine whether a potential customer or an existing customer is a PEP;
c) ensuring that decisions to enter into business relationships with PEPs are only taken by senior management; and
d) ensuring that business relationships which are known to be related to PEPs must be subject to proactive monitoring of the activity
on such accounts.
A15. The following controls amongst others need to be implemented for correspondent banking relationships:
a) a firm must gather sufficient information about a respondent institution to fully understand the nature of their business;
b) senior management approval must be obtained prior to establishing new correspondent relationships; and
c) the firm must assess the respondent institutions AML and terrorist financing controls.
.
A16. Yes.
a)
b) a firm must
senior gather sufficient
management approvalinformation about a prior
must be obtained respondent institution
to establishing to correspondent
new fully understandrelationships;
the nature ofand
their business;
b)
c) senior
the firmmanagement
must assessapproval must beinstitutions
the respondent obtained prior
AMLtoand
establishing new correspondent
terrorist financing controls. relationships; and
c) the firm must assess the respondent institutions AML and terrorist financing controls.


A16. Yes.
A16. Yes.
A17. The additional controls required in respect of non face-to-face customers are:
A17. The a)
additional controls
ensuring required
that the in respect
customers of non
identity face-to-face
is established bycustomers
additional are:
documents, data or information;
a) ensuring that the
b) supplementary customers
measures identity
to verify theisdocuments
establishedsupplied,
by additional documents,
or requiring data or
an eligible information;
introducer to certify the customer identification
b) documents;
supplementary andmeasures to verify the documents supplied, or requiring an eligible introducer to certify the customer identification
documents;
c) ensuring thatand
the first payment of the operation is carried out through an account in the customers name at a credit institution.
c) ensuring that the first payment of the operation is carried out through an account in the customers name at a credit institution.
A common mechanism adopted by many firms is to permit the use of certified customer identification documents provided in lieu of having
A common
had sight ofmechanism adopted by many firms is to permit the use of certified customer identification documents provided in lieu of having
the originals.
had sight of the originals.
Reporting
Reporting
A18. Gibraltar Financial Intelligence Unit, which is a member of the Egmont Group.
A18. Gibraltar Financial Intelligence Unit, which is a member of the Egmont Group.

Q20. Are there any
threshold, obligations
international to report
wire anything
transfers, other more than suspicious
transactions etc.? transactions e.g. unusual transactions, cash transactions above a certain
A20. No.
A20. No.
A21. No.
A21. No.
A22. There are three offences that could be committed by an individual:

A22. There
a) areAssistance;
three offences that could be committed by an individual:
a) Assistance;
b) tipping off; and;
b) tipping
c) off;
failure to fileand;
a SAR.
c) failure to file a SAR.
A23. No.
A23. No.
.
.This publication has been prepared for general guidance on matters of interest for the personal use of the reader, and does not constitute professional advice. You should not act upon the information
Yes. without for
obtaining
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on mattersadvice. The for
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A24.
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any liability,
Q25. Does

the
local legislation
All rights
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transactions to be monitoredlegal
each ofPricewaterhouseCoopers
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outside
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the jurisdiction?
of member firms of

A25. No.
www.pwc.com.
Germany
Key contact: Lars-Heiko Kruse Postal address: Last updated:
Email: lars-heiko.kruse@de.pwc.com Moskauer Str. 19; January 2013
Tel: +49 211 981 5854 D-40227; Dsseldorf; Germany
General
A1. 1993 (amended 2003, 2008 and 2011).
A2. N/A.
A3. According to section. 16 of the German Anti Money Laundering Act:

a) German Banking Supervisory Authority (BaFin) www.bafin.de
b) See above
c) Decentralised regulation, communal supervision in each of the 16 states of Germany e.g. Hessen:
http://www.hessen.de/irj/RPDA_Internet?cid=bed0fee03852d9e5286ceb90870b2356
A4. There is guidance in each of the 16 states, for example Hessen:

http://www.hessen.de/irj/RPDA_Internet?cid=bed0fee03852d9e5286ceb90870b2356
A5. Yes - in accordance with Section 3 paragraph 1 number 4 of the German Anti Money Laundering Act.
A6. Yes.
A7. Yes- in 2010. http://www.fatf-gafi.org/topics/mutualevaluations/documents/mutualevaluationofgermany.html
.
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context requires,
on it.
network
exercise of member
member of

A6. Yes.
Know
Yes- in 2010. http://www.fatf-gafi.org/topics/mutualevaluations/documents/mutualevaluationofgermany.html
A8. Yes one-off transactions below EUR15,000 (in total) and cash transactions in foreign coins and notes below EUR2,500.
.
Q9. What orare
agents do not accept the high
assume levelresponsibility
any liability, requirements for
or duty of verification of customer
care for any consequences identification
of you or anyone elseinformation (individuals
acting, or refraining and legal
to act, in reliance on theentities)?
information contained in this
A9. Individuals:
PricewaterhouseCoopers Evidence
International ofeach
Limited, identity has
of which is atoseparate
be provided by documentary
and independent legal entity. evidence. The
physical or electronic record of the individual should
contain the full name, address, date and place of birth and nationality. Documentary evidence can be a valid identity card or a passport,

diplomatic passports, passport replacement papers or resident permits.
Corporates that are listed in a public register: The physical or electronic record of the institute should contain firm, legal form, register
number, address, domicile and names of management. Evidence of identity has to be provided by a certificate of public registration.
Corporates that are not listed in a public register (partnership): The physical or electronic record of the institute should contain firm,
legal form, register number, address, domicile and names of management. Evidence of identity has to be provided by a partnership
agreement. In addition, the partners have to be identified like individuals.
A10. Individuals and Corporates:

In general, the physical presence of the individual (identification document: passport including a photograph of the individual) or an
authorised representative of the corporate (identification document: copy of the register) is required.
In exceptional cases (e.g. for online banks), trusted third parties, including other banks, insurance companies, notaries or the German Post,
are allowed to conduct the identification. In addition, the individual or an authorised representative of the corporate is allowed to send a copy
of the identification document certified by a notary, church or public administrator but the first transaction has to be received from an account
opened at another bank named in guideline 2005/60/EG or domiciled in a country with equivalent AML rules.
A11. The beneficial owner is the individual who is owner or ultimately controls the contracting party (ownership of 25% or more) or on whose
decision the transaction is ultimately initiated.
Documentary evidence has to be provided for the identification of a beneficial owner on the base of a risk-oriented approach..
A12. Reduced/simplified due diligence arrangements are possible where there is a reduced money laundering or terrorist financing risk. This
applies to transactions with other financial institutions, listed companies, domestic and some foreign authorities.
A13. Enhanced customer due diligence is required where there is a high risk of money laundering or terrorist financing. This generally applies to
transactions with Politically Exposed Persons (PEPs) and in cases of non face-to-face transactions.
Transactions and client relationships assessed as bearing a higher money laundering/terrorist financing risk, or where the company is
engaged in activities that are assessed to bear a higher money laundering risk, will require further verification and/or monitoring. For
example, those clients conducting complex transactions or clients in less transparent jurisdictions.
A14. Enhanced customer due diligence is required for all PEPs.
A15. In the case of correspondent banks based in European Union (EU) member states or member states of the Basel committee, it should be
ensured that a licence for monetary transfers exists. In the case of correspondent banks based in other countries, additional information
regarding the structure of management, ownership and the Articles of Association should be received.
.
Questions and
A13. Enhanced Answers:
customer due diligence is required where there is a high risk of money laundering or terrorist financing. This generally applies to

transactions with Politically Exposed Persons (PEPs) and in cases of non face-to-face transactions.
Transactions and client relationships assessed as bearing a higher money laundering/terrorist financing risk, or where the company is
engaged in activities that are assessed to bear a higher money laundering risk, will require further verification and/or monitoring. For
example,
Country by countrythose clients conducting
comparison complex
of high leveltransactions
Know Your or clients in less transparent
Customer jurisdictions.
A14. Enhanced customer due diligence is required for all PEPs.
A15. In the case of correspondent banks based in European Union (EU) member states or member states of the Basel committee, it should be
ensured that a licence for monetary transfers exists. In the case of correspondent banks based in other countries, additional information
regarding the structure of management, ownership and the Articles of Association should be received.
.
A16. Yes.
A17. Identification has to be carried out by so called trusted third parties (zuverlssiger Dritter) such as a bank that offers face-to-face transfers,
a notary, a life insurance company or the German Post AG. The third party sends the documentation and a copy of the documentary
evidence to the firm that does not offer face-to-face transactions. If this firm ensures that another trusted third party fulfils the German AML
Regulations, the identification can be done by another trusted third party. In addition, the first transaction has to be received from an account
opened at another bank named in guideline 2005/60/EG or domiciled in a country with equivalent AML rules.
Reporting
A18. According to Section 10 and 11 of the German Anti Money Laundering Act:
To the Criminal Investigation Department of the relevant state and to the central Criminal Investigation Department of Germany (Central
Division for Suspicious Activity Reports -(Financial Intelligence Unit -FIU))

2010 11,042 SARs (FIU)

A20. Until January 2012, only suspicious transactions had to be reported. However due to the findings of the FATF the German Anti Money
Laundering Act was updated in December 2011. The internal threshold to report an unusual transaction or behaviour is nowlower.
A21. No.
A22. Yes - section. 17 I no. 8 of the German Anti Money Laundering Act outlines the penalties for not reporting, an incorrect report of an unusual
transaction, an incomplete report or one not made in the correct timeframe.
A18. According to Section 10 and 11 of the German Anti Money Laundering Act:
To the Criminal
threshold, Investigation
international Department
wire transfers, of the
other relevant state
transactions etc.? and to the central Criminal Investigation Department of Germany (Central
Division for Suspicious Activity Reports -(Financial Intelligence Unit -FIU))
Know
A20.
Until January 2012, only suspicious transactions had to be reported. However due to the findings of the FATF the German Anti Money
Laundering
What Act
was the was updated
volume of SARsin Decemberthe2011. The internal threshold
recenttoand
reportPlease
an unusual
state transaction
GDP fororthe
behaviour is nowlower.
Q19. by country
Country comparison ofmade
hightolevelauthorities
Know Your in theCustomer
most year?Anti-Money the
Laundering equivalent
informationyear.

2010 11,042
Are there SARs (FIU)thresholds below which transactions do not need to be reported?
any de-minimis
Q21.
GDP
No. (in current prices):
A21. 2010 USD3,280,530 million (Source: data.worldbank.org * )
threshold, international
Yes - section. 17 I no. 8wire transfers,
of the Germanother
Anti transactions etc.? Act outlines the penalties for not reporting, an incorrect report of an unusual
Money Laundering
A22. transaction, an incomplete report or one not made in the correct timeframe.
A20. Until January 2012, only suspicious transactions had to be reported. However due to the findings of the FATF the German Anti Money
Laundering Act was updated in December 2011. The internal threshold to report an unusual transaction or behaviour is nowlower.
A23. Yes, according

* GDP at purchaser's to sec.
prices is the sum 25value
of gross II ofadded
the German Banking
by all resident Act.
producers in the economy plus any product taxes and minus any subsidies not included in the value of the products. It is
.A21. No.
A24. Yes, sec. 11 of the German Anti Money Laundering Act
A22. Yes - section. 17 I no. 8 of the German Anti Money Laundering Act outlines the penalties for not reporting, an incorrect report of an unusual
Q25. Does the local
transaction, an legislation
incompleteallow transactions
report to be monitored
or one not made outside
in the correct the jurisdiction?
timeframe.
A25. Yes.
.
www.pwc.com.
France
Key contact: Ludivine Gimet / Nicolas Montillot Postal address: Last updated:
Email: ludivine.gimet@fr.pwc.com / Crystal Park; 63 rue de Villiers; 92208 January 2013
nicolas.montillot@fr.pwc.com Neuilly-sur-Seine Cedex; France
Tel: +33 (0) 1 56 57 7565
General
A1. Fully revised with the transposition of the third AML Directive on 30 January 2009.
A2. The requirements of the previous AML regime already included KYC, monitoring of transactions and Suspicious Transactions Reporting.
However, the former regime did not allow risk-based approaches for due diligence depending on the AML risk scoring of customers,
transactions and products; the scope of Suspicious Transaction Reporting did not include transactions relating to tax fraud; there was no
definition of a Politically Exposed Person (PEP); and collaboration between regulated entities was not recognised.
A3. a) Autorit de Contrle Prudentiel (ACP): http://www.banque-france.fr/supervision-et-reglementation/acp.html#header

b) Autorit des Marchs Financiers (AMF) (and ACP if the subsidiary of a bank): http://www.amf-france.org/
c) Autorit de Rgulation des Jeux en ligne (ARJEL): http://www.arjel.fr/ for online games, casinos etc.
A4. Yes, guidelines have been developed by ACP regarding the:

a) business relationship and occasional customer
b) beneficial ownership
c) third party introduction
d) exchange of information within a group and non-group
e) reporting suspicious
f) politically exposed persons
Sources of practical guidance includes:
a) http://www.acp.banque-france.fr/controle-prudentiel/lutte-contre-le-blanchiment-des-capitaux-et-le-financement-du-terrorisme.html
b) http://www.amf-
france.org/resultat_simple.asp?slttypeinfo=site&iFullTextQuery=blanchiment+des+capitaux%60%22blanchiment+de+capitaux%2
2&iLanguage=French&iDatabaseSelection=AMFCMR
c) http://www.economie.gouv.fr/tracfin
d) http://www.fbf.fr/fr/environnement-europeen-et-international/lutte-anti-blanchiment/_875GT2&Count=8
e) http://www.arjel.fr/-Textes-de-reference-.html
A5. Yes.
A6. No - each institution must implement a risk-based approach which defines the required due diligence depending on the money-laundering
risks associated with the customer, product, transaction and means of distribution. Regulation provides examples of low and high risk
customers, products, transactions and means of distribution but these lists are not exhaustive. Each institution must define their own risk
mapping of customers, products, transactions and means of distribution and the associated due diligence required. This risk-based
. approach is not validated by the local regulator(s) but periodically examined during on site reviews.
2013 PwC.
accept reserved.
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Q7.
context requires,
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or for anythe
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member (orfirm
FATF-style) Mutual
is a separate legal entity Evaluation oras
and does not act IMF
agentassessment
of PwCIL or anyexercise in the
other member firm.last three
PwCIL doesyears? If any
not provide yes,services
to clients. PwCIL is not responsible
please or liable
find a link to a for the acts or
relevant omissions
report of any of its
(if publicly member firms nor can it control the exercise of their professional judgment or bind them in any way. No member firm is
available).

A7. Yes, the anti-money laundering and countering the financing of terrorism (AML/CFT) measures in place in France have been evaluated by
the FATF in 2010 (18 January - 2 February 2010)
Questions
A6. No - eachand Answers:
institution must implement a risk-based approach which defines the required due diligence depending on the money-laundering

risks associated with the customer, product, transaction and means of distribution. Regulation provides examples of low and high risk
customers, products, transactions and means of distribution but these lists are not exhaustive. Each institution must define their own risk
mapping of customers, products, transactions and means of distribution and the associated due diligence required. This risk-based
approach is not validated by the local regulator(s) but periodically examined during on site reviews.
A7. Yes, the anti-money laundering and countering the financing of terrorism (AML/CFT) measures in place in France have been evaluated by
the FATF in 2010 (18 January - 2 February 2010)
http://www.fatf-gafi.org/countries/d-i/france/documents/mutualevaluationoffrance.html
A8. Yes - The identification of occasional customers is not required for any transaction they carry out under EUR 8,000 if the transaction is not
deemed suspicious.
A9. Individuals: a government-issued document with a photograph (such as a valid passport or a valid photocard driving licence), supporting
documents of home address at the date when the documents are collected, occupation, revenues or any other relevant documents which
enable to assess the clients resources and his personal assets.
Legal entities: original or certified copy of any deed or extract of an official register stating the company name, address, legal status and
identity of the executives, annual reports of the last 3 years and auditors reports.
A10. Individuals: Original identification documentation must be provided. A bank's employee is required to make a copy of the original
documentation and certify it true to the original.
Legal entities: Except in the specific case of the presentation of a certified copy of any deed or extract of an official register stating the
name, legal form and registered office, documentation provided should be the original with a copy certified by the bank's employee.
A11. The institution shall identify the effective beneficiary of the business relationship through any means it deems adequate and necessary. It
should verify that this identity is based on the documents collected, according to the assessed level of money laundering risk and the
documentation shall be kept on record.
A12. Due diligence may be reduced when the money laundering risks associated with a given customer and/or business relationships are
considered as low. Low risk customers include financial institutions subject to equivalent AML regulation, large corporates whose shares are
listed on a regulated stock-exchange incorporated in an EU-country or an equivalent third-party country and public administrative bodies or
authorities of an EU country. Low risk products include life insurance contracts with an annual premium under EUR1,000 or with a unique
premium under EUR2,500
A13. Enhanced customer due diligence measures are required in the following cases:
. a) when the client or his representative is not physically present for the account opening;
b) prepared
This publication has been when the clientguidance
for general is a Politically
on mattersExposed Person
of interest for ('PEP');
the personal use of the reader, and does not constitute professional advice. You should not act upon the information
c) whenwithout the
obtaining specific professional
transaction advice. The
or the financial application and
instrument impact of laws
facilitates the can vary widelyof
anonymity based
the on the specific facts involved. No representation or warranty (express
client;
agents do not accept or assume any liability, responsibility or duty of care for any consequences of you or anyone else acting, or refrainingincorporated
d) when the transaction is carried out by individuals who live or corporates which are to act, in relianceinonnon-cooperative countries;
the information contained in this and
publication or for any e) when
decision basedthe transaction is complex, of an unusual amount or without obvious justification.
on it.
A14. The regulation requires institutions to conduct additional due diligence for PEPs in all cases as these clients are systematically considered
as high risk clients.
Questions a) and
customer due diligence measures are required in the following cases:
when the client or his representative is not physically present for the account opening;

b) when the client is a Politically Exposed Person ('PEP');
c) when the transaction or the financial instrument facilitates the anonymity of the client;
d) when the transaction is carried out by individuals who live or corporates which are incorporated in non-cooperative countries; and
Country by country
e) whencomparison ofishigh
the transaction levelofKnow
complex, Your
an unusual Customer
amount and
or without Anti-Money
obvious Laundering information
justification.
A14. The regulation requires institutions to conduct additional due diligence for PEPs in all cases as these clients are systematically considered
as high risk clients.
A15. Institutions must :

a) collect sufficient information on its correspondent banking relationships activities and assess, based on publicly available
information, its reputation;
b) assess its anti-money laundering arrangements;
c) ensure that the decision of establishing this relationship has been approved by an executive of the institution;
d) include in the correspondent-banking agreement the requirements to provide the institution with information on demand; and
e) ensure that the correspondent-banking counterparty has checked the identity of its clients, when the institution has opened
accounts which are directly used by the correspondent-banking clients for their own transactions.
A16. Yes.
A17. Regulation requires institutions to systematically conduct enhanced due diligence for non face-to-face transactions and/or relationships, i.e.
relationships considered as high-risk in terms of money-laundering.
Reporting
A18. Tracfin (Traitement du renseignement et action contre les circuits financiers clandestins): http://www.tracfin.bercy.gouv.fr/

2011 22,856 SARs, divided as follows: Financial sector: 21,165; Non-financial sector: 1,691 (Source: Tracfin annual report)

threshold,
* GDP at purchaser's international
prices is the sum of gross wire transfers,
value added by allother
residenttransactions
producers in theetc.?
economy plus any product taxes and minus any subsidies not included in the value of the products. It is
. A20. Yes.
a) prepared
This publication has been operations which
for general are particularly
guidance complex,
on matters of interest for thean amount
personal which
use of appears
the reader, to be
and does unusually
not constitute high oradvice.
professional does You
notshould
appear
not to
act have any
upon the information
economic justification, where the bank is unable to establish the identity of the beneficiary or obtain sufficient information
agents do not accept or assumeregarding theresponsibility
any liability, origin andordestination
duty of care forfund, the commercial
any consequences of you or background or the
anyone else acting, legalityto of
or refraining act,aintransaction;
reliance on the information contained in this
publication or for any b) any
decision transaction
based on it. for which the identity of the originator or the beneficiary could not be established.
A21. No.
A22. Yes.
d) include in the correspondent-banking agreement the requirements to provide the institution with information on demand; and
e) ensure
Are there that the correspondent-banking
any obligations to report anything more counterparty hastransactions
than suspicious checked thee.g.
identity of itstransactions,
unusual clients, whencash
the institution
transactionshasabove
opened
a certain
Q20. threshold,accounts which
international aretransfers,
wire directly used
otherby the correspondent-banking
transactions etc.? clients for their own transactions.
Questions
Yes.
A20. Are and Answers:
relationships with which
shell banks specifically prohibited?
Q16.
a) operations are particularly complex, an amount which appears to be unusually high or does not appear to have any
economic justification, where the bank is unable to establish the identity of the beneficiary or obtain sufficient information
Yes. regarding the origin and destination fund, the commercial background or the legality of a transaction;
A16. b) any transaction for which the identity of the originator or the beneficiary could not be established.
Q17. In what
Are circumstances
there is additional
any de-minimis thresholdsdue diligence
below whichrequired for non
transactions face-to-face
do not transactions
need to be reported? and/or relationships?
Q21.
A17. Regulation
No. requires institutions to systematically conduct enhanced due diligence for non face-to-face transactions and/or relationships, i.e.
A21. relationships considered as high-risk in terms of money-laundering.
Reporting
A22. Yes.
A18. Tracfin (Traitement du renseignement et action contre les circuits financiers clandestins): http://www.tracfin.bercy.gouv.fr/
A23. No.
2011
Yes The
22,856 SARs, divided
transaction as follows:
is on hold Financial
until Tracfin sector: 21,165; Non-financial sector: 1,691 (Source: Tracfin annual report)
approval.
A24.
A25. Yes - if it concerns a country of the European Union or a country which imposes equivalent rules to France with regard to the fight against
Money Laundering and Terrorist Financing.
.
.
www.pwc.com.
Finland
Key contact: Ake Turunen Postal address: Last updated:
Email: ake.turunen@fi.pwc.com Itamerentori 2; FIN-00180 Helsinki; January 2013
Tel: +358 9 2280 1978 Finland
General
A1. 2008 (original 1998, amended 2003)
A2. In general, previous AML laws followed previous European Union ('EU') directives.
A3. (a) Financial Supervisory Authority http://www.fin-fsa.fi

(b) Financial Supervisory Authority http://www.fin-fsa.fi
(c) Ministry of the Interior and Regional State Administrative agencies
A4. Yes guidance is provided by the Money Laundering Clearing House of Finland (operates within the National Bureau of Investigation (NBI) -
www.poliisi.fi/nbi .
A5. Yes - based on a risk-based assessment.
A6. Yes.
A7. Yes. please see link: http://www.fatf-gafi.org/topics/mutualevaluations/documents/mutualevaluationoffinland.html
A8. Yes - one-off transactions below EUR15,000, provided that there is no reason to suspect that the assets or other property involved in a
transaction are of an illegal nature or are used to commit (or attempt to commit) an offence of money laundering or financing terrorism.
.
Q9. What
rights are
2013 PwC. All
as to thethe high
for level
accuracy
reserved. Not furtherrequirements
distribution withoutfor
or completeness
theverification
of the information contained of customer
in this
permission of PwC. identification
publication,
PwC refers information
and, to the extent
to the network of member firms(individuals and legal entities)?
permitted by law, PricewaterhouseCoopers
of PricewaterhouseCoopers
LLP, its members, employees and
International Limited (PwCIL), or, as the
to the
of another
network of membermember
firms firms
of

Individuals: full name, date of birth, identification number (for foreign citizens: citizenship and passport number). Required documents for
individuals: passport, driving licence or official identity card.
Know
Yes - one-off transactions below EUR15,000, provided that there is no reason to suspect that the assets or other property involved in a
transaction are of an illegal nature or are used to commit (or attempt to commit) an offence of money laundering or financing terrorism.
Individuals: full name, date of birth, identification number (for foreign citizens: citizenship and passport number). Required documents for
individuals: passport, driving licence or official identity card.
Legal entities: name, business identification number, date of registration (and name of registration authority), field of activity as well as full
name, date of birth and citizenship of members of the statutory bodies and the person(s) representing the legal entity. Required documents
for legal entities: trade register extract or equivalent official extract from a relevant public register and relevant documents for the individuals
previously mentioned.
A10. A certified copy signed by two qualified individuals is required. The qualified individual does not have to be a notary, lawyer or accountant.
A11. The name, date of birth and identification number of the beneficial owner(s) (for foreign citizens: citizenship and passport number) must be
verified.
A12. Reduced/simplified due diligence arrangements are available if the risk of money laundering or financing terrorism connected to the
customer, product, service or field of activity is low. For example, simplified due diligence arrangements are available to Finnish authorities;
public companies listed on the Finnish or any other European Economic Area ('EEA') country exchange; credit institutions, financial
institutions, investment firms, management companies/custodians and insurance companies with concession in Finland or another EEA
country.
A13. Enhanced due diligence measures are required if there is a high risk of money laundering or financing terrorism in connection to the
customer, product, service or field of activity. Enhanced due diligence is also required if the transaction is connected to a state in which
systems for preventing and clearing money laundering does not meet international standards.
A14. Additional due diligence is required if the customer himself is a PEP or is related to a PEP, or is an individual who is known to be the
business partner of a PEP.
A15. Firstly, the management of the credit institution has to approve the correspondent banking relationship. Should it be approved, the credit
institution has to collect sufficient information about the correspondent bank which includes evaluating the bank's reputation, the quality of its
supervision and the correspondent bank's measures to prevent money laundering and financing terrorism.
A16. No.
.
A17. Additional
PricewaterhouseCoopers due diligence
International Limited, is always
each required
of which if the
is a separate andcustomer
independent is notentity.
legal physically present for identification.
Reporting
A16. No.

Know
Additional due diligence is always required if the customer is not physically present for identification.
A16. byNo.
Reporting
Q18. To whom are
Additional dueSuspicious
diligence isActivity
alwaysReports
required(SARs) made? Please
if the customer include a link
is not physically to their
present for website.
identification.
A17.
A18. Money Laundering Clearing House of Finland, which operates within the NBI.
Reporting
2011 28,378 SARs
A18. Money Laundering Clearing House of Finland, which operates within the NBI.
Q19. What was the

This results involume of 1SARs
a ratio of SAR made to the
for every authorities
USD9.3 millioninof
the most recent year? Please state the GDP for the equivalent year.
GDP.

Q20. 2011 28,378
Are there SARs
A20. No.
A21. No.
A20. No.
Q21. Are
Yes.there any de-minimis thresholds below which transactions do not need to be reported?
A22. a) Violation of customer due diligence: fine, unless a more severe punishment for the act is provided elsewhere in the law.
A21. No. b) Registration violation: fine, unless a more severe punishment for the act is provided elsewhere in the law.
c) Violation of the obligation to report money laundering: fine
d) Payment service violation: fine, unless a more severe punishment for the act is provided elsewhere in the law
A22. Yes.
A23. No. a) Violation of customer due diligence: fine, unless a more severe punishment for the act is provided elsewhere in the law.
b) Registration violation: fine, unless a more severe punishment for the act is provided elsewhere in the law.
c) Violation of the obligation to report money laundering: fine
d) Payment service violation: fine, unless a more severe punishment for the act is provided elsewhere in the law
Q23. Are
No. there any requirements (legal or regulatory) to use automated Suspicious Transaction monitoring technology?
A24.
A23. No. prices is the sum of gross value added by all resident producers in the economy plus any product taxes and minus any subsidies not included in the value of the products. It is
Q25. Doesusing
domestic currencies the single
localyear
legislation allow rates.
official exchange transactions to be monitored
For a few countries outside
where the official the rate
exchange jurisdiction?
does not reflect the rate effectively applied to actual foreign exchange transactions, an
.
Q24. Is
This publicationNo.there
has beenaprepared
requirement to guidance
for general obtain authority tointerest
on matters of proceed with
for the a current/ongoing
personal transaction
use of the reader, and that isprofessional
does not constitute identifiedadvice.
as suspicious?
You should not act upon the information
A25.
*GDP
2009atPricewaterhouseCoopers.
calculated
All rights
purchaser's prices is the sum
without making International
deductions for
reserved.
of gross
Limited, each of
depreciation
value added
ofwhich
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refers
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and minus any subsidies not included in the value of the products. It is
entity. of natural resources. Data are in current U.S. dollars. Dollar figures for GDP are converted from
degradation
.
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organisations andconsequences
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158the information
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Denmark
Key contact: Ole Fabricius Postal address: Last updated:
Email: ofa@pwc.dk Strandvejen 44, January 2013
Tel: +45 3945 3471 DK 2900 Hellerup, Denmark
General
A1. 1993 (significant amendments in 2006, 2008, 2009, 2010 and 2012)
A2. N/A.
A3. a) The Danish FSA,( http://www.finanstilsynet.dk) ,

b) The Danish FSA,( http://www.finanstilsynet.dk ),
c) Business Registry Authority (http://www.erst.dk/ ), Lawyer: The Danish Bar and Law Society (http://www.advokatsamfundet.dk )
A4. A Danish general guidance is issued by the Danish FSA. http://www.finanstilsynet.dk/da/Temaer/Hvidvask/Regler.aspx

Furthermore, the Danish Business Authority has issued guidance for specific sectors e.g. accountancy sector,
http://www.eogs.dk/sw22201.asp
A5. Yes - but a company can postpone confirmation of the identification of customers using a risk based approach and based on any previous
relationship with the customer.
A6. A risk based approach is allowed in accordance with law. However, the actual approach has to be approved as being consistent with the
AML regulations.
A7. http://www.fatf-gafi.org/countries/d-i/denmark/documents/follow-upreporttothemutualevaluationofdenmark.html
.
2013 PwC.
accept reserved.
assumeNot
consequences refers
context requires,
on it.
network
exercise of member
member of

A6. A risk based approach is allowed in accordance with law. However, the actual approach has to be approved as being consistent with the
AML regulations.
Questions
Know
A7.
http://www.fatf-gafi.org/countries/d-i/denmark/documents/follow-upreporttothemutualevaluationofdenmark.html
.
A8. Yes - one-off transactions below EUR 15,000 using a risk based approach.
A9. Individuals: name, address and social security number. Accepted evidence includes: passport, driving license, birth certificate, tax returns
and tax code (including social security number). Electronic public keys will also be accepted.
Corporates: name, address and company number. Accepted evidence includes: Registered information from the Danish Commerce and
Companies Agency and Articles of Association.
A10. There are no mandatory requirements in the law, but it is stated in local guidance that copies of identification documentation are accepted.
Copies of documentation can be certified by financial institutions according to the law.
A11. Identification of the beneficial owner has to be known. The group structure or ownership of a group has to be identified as well as
shareholders who own more than 25% of a company.
A12. Customer due diligence is reduced in three main areas:

a) payments for life insurance or under pension agreements under specific circumstances e.g. payments of EUR1,000 or less for
recurring fees and a one time fee of EUR2,500 or less;
b) electronic money - if the device cannot be recharged and the maximum amount stored in the device is no more than EUR250, or
where, if the device can be recharged, a limit of EUR2,500 is imposed on the total amount transacted in a calendar year, except
when an amount of EUR1,000 or more is redeemed in that same calendar year; and
c) specific transactions and products as described by the Danish Financial Services Agency (FSA) in order no. 712 of 2008.
A13. Local guidance states four cases:

a) customers who do not physically present themselves for identification purposes;
b) cross-border correspondent banks;
c) Politically Exposed Persons ('PEPs'); and
d) shell companies.
A14. Legislation requires financial institutions to:

a) have sufficient procedures to determine whether the customer is a PEP who is a resident of another country;
b) obtain approvals from senior management on a daily basis for establishing business relationships with such customers;
c) take reasonable measures to gather information about the sources of income and funds that are involved in the business
relationship or transaction; and
d) continuously monitor the business relationship.
.

Questions
a) and Answers:
have sufficient procedures to determine whether the customer is a PEP who is a resident of another country;

c) take reasonable measures to gather information about the sources of income and funds that are involved in the business
A15. In cases of money transfers to or from a bank outside the European Union ('EU') where there is no official agreement of financial services
with the EU, further proceedings have to be considered as stated in the local guidance. Before establishing new correspondent banking
relationships, firms will be required to:
a) gather sufficient information about a respondent institution to understand fully the nature of the respondent's business and to
determine from publicly available information the reputation of the institution and the quality of supervision;
b) assess the counterparty's AML and anti-terrorist-financing controls; and
c) obtain approval from senior daily management, etc.
.
A16. Yes. All rights reserved. PricewaterhouseCoopers refers to the network of member firms of
A17. In the case of a customer who has not been physically present for identification purposes, legislation requires the taking of 'further measures
to ascertain the customers identity'. It sets out an illustrative list of measures that can be taken to ascertain the customers identity in these
situations, such as: ensuring that the customer's identity is established by additional documentation; checking or verifying the documents
supplied, or requiring a confirmatory certification by another financial institution; and requiring that the first payment in connection with the
transactions is carried out through an account opened in the customer's name with a bank.
Reporting
A18. The Danish Money Laundering Secretariat hosted by the State Prosecutor for Serious Economic Crime
http://www.rigsadvokaten.dk/?id=215

2011 3.020 SARs

2011 USD333,616 billion (Source: data.worldbank.org* )
A20. Any violation of money laundering or terrorist financing has to be reported immediately and the suspect can be punished by 1 year
imprisonment.
A21. Staff members are not required to have knowledge of what crimes can be in violation of the law and punishable by 1 year. Therefore staff
members must report internally to a compliance officer, who afterwards decide whether to report to the State Prosecutor for Serious
Economic Crime or not.
*
.
A18. The Danish Money Laundering Secretariat hosted by the State Prosecutor for Serious Economic Crime
http://www.rigsadvokaten.dk/?id=215
Know
Q19.
2011 3.020 SARs
*
2011 USD333,616
Any penalties will be billion
handled (Source: State Prosecutor for)Serious Economic Crime,In certain cases this can be up to 6 months
by the data.worldbank.org
A22. imprisonment.
A23. Companies must have administrative procedures in place. Financial companies are considered to be operating in high risk sector and
therefore automatic monitoring of transactions is required by the Danish FSA.
A20. Any violation of money laundering or terrorist financing has to be reported immediately and the suspect can be punished by 1 year
imprisonment.
A24. Thethere
Are Stateany
Prosecutor for Serious
de-minimis Economic
thresholds Crimetransactions
below which has to report
doback by thetoend
not need of the following banking day.
be reported?
Q21.
A21. Staff members are not required to have knowledge of what crimes can be in violation of the law and punishable by 1 year. Therefore staff
members
Does the must report internally
local legislation allow to a compliance
transactions officer,
to be who afterwards
monitored outside thedecide whether to report to the State Prosecutor for Serious
jurisdiction?
Q25. Economic Crime or not.
A25. No
*
.
people who
does not services.
You and find
should not out
act more
upon by
thevisiting us at
information
www.pwc.com.
onto the extent
matters permitted
law,does
advice. employees
upon
without or anyone
warranty contained
or implied)
any liability,
separate
of caretofor
decision
theany
based on
independent
consequences
network of member
it. entity.
legal
offirms
you or

Czech Republic
Key contact: Sirshar Qureshi Postal address: Last updated:
Email: sirshar.qureshi@cz.pwc.com Hvzdova 1734/2c January 2013
Tel: +420 2 5115 1235 140 00 Praha 4
Czech Republic
General
A1. 1996 (amended 2004, 2006 and 2008 - Act No. 253/2008 Coll. effective as of 1 September 2008) and last amended 2012
http://www.mfcr.cz/cps/rde/xchg/mfcr/xsl/leg_aml_cft.html
.
A2. N/A.
A3. The key regulator for AML controls is: Ministry of Finance of the Czech Republic - Financial Analytical Department (FAU) -
http://www.mfcr.cz/cps/rde/xchg/mfcr/xsl/ochrana_ekonom_zajmu_13891.html
Controls are also further performed also by (refer to Section 35 of the Act 253/2008 Coll.):
Czech National Bank www.cnb.cz In accordance with Act No. 6/1993 Coll., on the Czech National Bank (pdf, 190 kB), the Czech National
Bank is a supervisory authority of the financial market in the Czech Republic.
Czech Trade Inspectorate www.coi.cz/en/ - Administrative authorities supervising lotteries and other similar games, and holders of
licences to operate betting games.
A4. Yes Guidelines for submitting AML notifications issued by the Ministry of Finance -
http://www.mfcr.cz/cps/rde/xchg/mfcr/xsl/rt_bppp_oznameni_podez_obchodu.html
Guidelines issued by Czech National Bank -
http://www.cnb.cz/cs/dohled_financni_trh/legislativni_zakladna/legalizace_vynosu/metodiky_vyklady.html
A5. No.
A6. Yes the Czech National Bank stipulates in Guidance 281/2008, that financial and credit institutions should implement the risk based
approach when assessing the risk of legitimisation of proceeds of crime and financing of terrorism. The institutions should take into
consideration the best practices applied in this area. Furthermore, the Czech National Bank issued its official ruling on 26 May 2009 in which
it specifies the respective AML standards:
http://www.cnb.cz/miranda2/export/sites/www.cnb.cz/cs/legislativa/vestnik/2009/download/v_2009_08_21109560.pdf
A7. MONEYVAL assessment - April 2011 - http://www.coe.int/t/dghl/monitoring/moneyval/Countries/Czech_en.asp

.
A8. Yes - any single transaction below EUR 15,000 does not require any customer due diligence unless it is a:
a) A suspicious transaction;
c) an agreement to establish an account, to make a deposit into a deposit passbook or a deposit certificate, or to make any other type
of deposit;
e) a transaction with a Politically Exposed Person ('PEP'); and
f) as part of the business relationship.
Individuals: Name, surname, birth identification number or date of birth, place of birth, sex, address and citizenship. These would normally
be verified by an identity card or passport.
Individuals who conduct business: In addition to the above, full name of the business, place of business and identification number needs
to be noted.
Legal entities: the full name, residency/seat, identification (or similar identification received from foreign offices) showing evidence of the
companys existence (i.e. certificate of incorporation, trade register statement or other). The same principles for 'Individuals' apply for the
identification of individuals in the companys statutory body. If the companys statutory body or the owner is another legal entity,
identification documentation must also be collected for that entity.
A10. These should be certified by an appropriate person e.g. a notary, local authorities etc.
Specific rules apply to credit and financial institutions, where certain employees are authorized to verify these when opening account,
concluding contract etc.
A11. The shareholders of a legal entity (with more than 25% holding) must be ascertained. Identification requirements are the same as for the
relevant legal entity.
A12. Simplified due diligence is applicable for a transaction exceeding EUR1,000 unless it is a:
a) suspicious transaction;
c) an agreement to establish an account, to make a deposit into a deposit passbook or a deposit certificate, or to make any other type
of deposit;
e) a life insurance contract, should the customer have a right to pay extra premiums above the agreed limit of the one-off or regular
premiums payments;
f) a purchase or receipt of cultural heritage, items of cultural value, used goods or goods without a receipt of origin to further trade in
such goods, or receipt of such items in pawn; or
g) withdrawal of the final balance of a cancelled bearer passbook.

a) a remote financial services agreement under the Civil Code;
.
g) withdrawal of the final balance of a cancelled bearer passbook.
a) a remote financial services agreement under the Civil Code;

a) have sufficient procedures to determine whether the customer is a PEP who is a resident of another country;
. c) take reasonable measures to gather information about the sources of income and funds that are involved in the business
A15. All transactions with PEPs are subject to due diligence including the provision of information and supporting documentation relating to:
a) the purpose and intended nature of the transactions or business relationship;
b) the beneficial owner, if the client is a legal entity;
c) the information required for continuous monitoring of the business relationship; and
d) a review of the income source.
A16. Yes.
A17. In the case of a remote financial services agreement under the Civil Code, the entity shall review the customer as follows:
a) the first payment under this agreement shall be made via an account kept in the customer's name held at a credit institution or a
foreign credit institution operating in the European Union ('EU') or the European Economic Area ('EEA');
b) the customer shall submit to the entity a copy of a document verifying the existence of this account together with copies of the
relevant parts of his identity card and at least one more identification document to validate the customer's identification data of this
card i.e. the type, serial number, issuing country or institution and validity.
Reporting
A18. Ministry of Finance of the Czech Republic - Financial analytical department (FAU)

2011 1,970 SARs (Source: http://www.mfcr.cz/cps/rde/xchg/mfcr/xsl/analit_cinn_kontr.html)

2011 USD217 billion (Source: data.worldbank.org* )
A20. Suspicious transactions are identified based on criteria such as unusual transactions, international wire transfers etc. However, no special
report is required.
A21. No.
*
.
Reporting
Know
Ministry of Finance of the Czech Republic - Financial analytical department (FAU)
Q19. What was any

Are there the volume of for
penalties SARs
nonmade to the authorities
compliance in the
with reporting most recente.g.
requirements year? Please
tipping off?state the GDP for the equivalent year.
Q22.
A19. Volume of SARs:are described in detail in Section 43 to 53 of the Act No. 253/2008 Coll.
Yes penalties
A22. 2011 1,970 SARs (Source: http://www.mfcr.cz/cps/rde/xchg/mfcr/xsl/analit_cinn_kontr.html)

*
2011 USD217
Are there billion (Source:
any requirements data.worldbank.org
(legal ) automated Suspicious Transaction monitoring technology?
or regulatory) to use
Q23.
A23. No, however, transaction monitoring should be performed by using adequate means which assumes use of some automated technology.
threshold, international to obtain
wire authority
transfers, to transactions
other proceed withetc.?
a current/ongoing transaction that is identified as suspicious?
A24. Yes - in general a transaction that is identified/reported as suspicious can be continued after 24 hours from the time when it has to be
A20. notified andtransactions
Suspicious received by are
the identified
Ministry ofbased
Finance, unlesssuch
on criteria the Ministry of Finance
as unusual requireinternational
transactions, to postponewire
the transaction.
transfers etc. However, no special
report is required.
A25. No.
A21. No.
*
.
www.pwc.com.
. any liability, responsibility or duty of care for any consequences of you or anyone else acting, or refraining to act, in reliance on the information contained
Cyprus
Cyprus th
Key contact: Chris Odysseos Postal address: Julia House 4th Floor, 3 Last updated:
Key contact: Chris Odysseos Postal address: Julia House 4 Floor, 3 Last updated:
Email: chris.odysseos@cy.pwc.com Themistocles Dervis Street, CY-1066, January 2013
Email: chris.odysseos@cy.pwc.com Themistocles Dervis Street, CY-1066, January 2013
Tel: +357 22 555 494 Nicosia, Cyprus
Tel: +357 22 555 494 Nicosia, Cyprus
General
General
A1. 1996.
A1. 1996.
A2. N/A.
A2. N/A.
Q3. Who
etc.).isPlease
the regulator
include for
linkAML controls
A3. a) Banking: Central Bank of Cyprus (www.centralbank.gov.cy)

A3. a)
b) Banking: CentralServices:
Other Financial Bank of Cyprus
CySEC(www.centralbank.gov.cy)
Cyprus Securities and Exchange Commission (www.cysec.gov.cy)
b)
c) Other FinancialSector:
Non-Financial Services:
UnitCySEC CyprusMoney
for Combating Securities and Exchange
Laundering (MOKAS)Commission (www.cysec.gov.cy)
(www.law.gov.cy/mokas/)
c) Non-Financial Sector: Unit for Combating Money Laundering (MOKAS) (www.law.gov.cy/mokas/)
Q4. Is there
local any practical
Please includeprovided to firms where
link to website, by public authorities regarding AML requirements, beyond the FATF recommendations and
available.
A4. The Institute of Certified Public Accountants of Cyprus (ICPAC) has issued a directive( ICPAC: Directive for the Prevention & Suppression
A4. The Institute
of Money of Certified
Laundering Public Accountants
& Terrorist of Cyprus
Financing Laws (ICPAC)
of 2007 has issued
and 2010) a directive(
that serves ICPAC:
as guidance to Directive for The
audit firms. the Prevention & Suppression
latest version was issued in
of Money Laundering
December 2011 as an&update
Terrorist
to Financing LawsinofMay
the one issued 20072008.
and 2010) that serves as guidance to audit firms. The latest version was issued in
December 2011 as an update to the one issued in May 2008.
A5. No.
A5. No.

A6. Yes.
A6. Yes.
Q7. Has thefind
please country
a linkbeen
to a the subject
relevant of a(if
publicly available). Mutual Evaluation or IMF assessment exercise in the last 3 years? If yes,
A7. Cyprus is being assessed by MoneyVal Council Of Europe.

A7. Cyprus is being assessed by MoneyVal Council Of Europe.
Customer due
due diligence
diligence
Customer
Q8. Are there
If Yes, minimum
in place?
A8. Yes, occasional transactions under EUR15,000 whether the transaction is carried out in a single operation or in several operations which
. appear to be linked.
.This publication has been prepared for general guidance on matters of interest for the personal use of the reader, and does not constitute professional advice. You should not act upon the information
This publication
publication withoutfor generalspecific
Thefor the personal
application and use
impactof the reader,
of laws canandvarydoes notbased
on the advice.
specific facts You should
involved. not act uponorthe
No representation information
warranty (express
contained
or implied)inisthis
givenpublication
as to thewithout
accuracyobtaining specific professional
or completeness advice.contained
of the information The application
in this and impact ofand,
publication, lawstocan
the vary widely
extent basedbyon
permitted thePricewaterhouseCoopers
law, specific facts involved. NoLLP,
representation
its members,or employees
warranty (express
and
or implied)
agents is given
do not acceptas or
to assume
the accuracy
any or completeness
liability, responsibilityof the
or information
duty of care contained
for any in this publication,
consequences of you and,
or to the extent
anyone else permitted
acting, or by law, PricewaterhouseCoopers
refraining to act, in reliance on the LLP, its members,
information employees
contained in this and
Q9.
2013 do
agents PwC.
not AllWhat
rights are the Not
reserved. high
any for
level
further requirements
distribution withoutfor theverification
permission of PwC. of customer
PwC refers identification
to the network of information
member firms(individuals and legal entities)?
of PricewaterhouseCoopers International Limited (PwCIL), or, as the
publication or accept
for any or assume
decision based liability,
on it. responsibility or duty of care for any consequences of you or anyone else acting, or refraining to act, in reliance on the information contained in this
context requires,
publication or for individual member
on it.of the PwC network. Each member firm is a separate legal entity and does not act as agent of PwCIL or any other member firm. PwCIL does not provide any services
to
clients.
A9.
2009
responsible
Individuals:
or liable
should
All
rightsfor
rights
acts or omissions
International
reserved.
provide
reserved.
of any
Limited,
Limited,
each
each
their full
is aname, nor date
other
of
of
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which is a
firm
separate
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and
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of birth,
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andit independent
control the
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exercise
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thefirms
at member
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theyprofessional
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firms can be located

judgmentand their
or bind profession
another member firmor oroccupation. An
PwCIL in any way.
The Design Group official
21383document
(01/13) bearing a photograph of the person should be obtained. It is important that the current permanent address should be
verified as it is an integral part of identity by requesting sight of a recent utility bill, local authority tax bill or bank or co-operative society
statement, or making a credit reference agency search.
Know
A8.
Yes, occasional transactions under EUR15,000 whether the transaction is carried out in a single operation or in several operations which
appear
Country by to be linked.
A9. Individuals: should provide their full name, date of birth, the address at which they can be located and their profession or occupation. An
official document bearing a photograph of the person should be obtained. It is important that the current permanent address should be
verified as it is an integral part of identity by requesting sight of a recent utility bill, local authority tax bill or bank or co-operative society
statement, or making a credit reference agency search.
Legal Entities: should provide full name, registration address, a copy of the latest report and accounts, a copy of the certificate of
incorporation/certificate of trade or equivalent, a copy of the companys Memorandum and Articles of Association and other certificates
issued by the Registrar of Companies, a group structure to identify individuals who control over 10% of the entitys shares or voting rights,
the names of the directors.
A10. The documents must be certified true copies of the originals.
A11. Due diligence measures comprise identifying the beneficial owner owning or controlling more than 10% of the shares or voting rights of the
client.
A12. According to paragraph 63-(1) of the Law:

Simplified customer due diligence and identifications procedures can be used in respect of the following:
(a) Credit of Financial Institution covered by the EU Directive or those who are situated in a country outside the European Economic
Area which (i) in accordance with a decision of the Advisory Authority for Combating Money Laundering and Terrorist Financing,
imposes requirements equivalent to those laid down by the EU Directive and (ii) it is under supervision for compliance with those
requirements;
(b) Listed companies whose securities are admitted to trading on a regulated market in a country of the European Economic Area or
in a third country which is subject to disclosure requirements consistent with community legislation; and,
(c) Domestic Public Authorities of countries of the European Economic Area.
A13. According to paragraph 64-(1) of the Law:

Enhanced due diligence measures should be in place in respect of the following customers:
(a) Where the customer has not been physically present for identification purposes;
(b) In respect of cross-frontier correspondent banking relationships with current institutions to customers from third countries; and
(c) In respect of transactions or business relationships with politically exposed persons (PEPs) residing in a country within the
European Economic Area or a third country.
According to paragraph 64-(2) of the Law:

Enhanced customer due diligence measures must be taken in all other instances which due to their nature entail a higher risk of money
laundering or terrorist financing.
A14. According to paragraph 4.53 of the Directive, if the prospective client is a PEP, the firm should obtain senior management approval for
establishing business relationship. In additionm according to paragraph 4.55 of the Directive, the firm should establish the source of wealth
and source of funds for PEPs and also conduct an ongoing monitoring on the business relationship.
Paragraph 4.56 of the Directive states that the firm should pay special attention when PEPs which originate from a country which is widely
known to face problems of bribery, corruption and financial irregularity and whose anti-money laundering laws and regulations are not
equivalent with international standards.
.
A15. According to 64 (b) of the Law, in respect of cross-frontier correspondent banking relationships with credit institutions to customers from
third countries, it is required to:
a) Gather sufficient information about the credit institution customer to understand fully the nature of the business and the activities
of the customer and to assess, from publicly available information, the reputation of the institution and the quality of its
supervision;
b) Assess the systems and procedures applied by the credit institution customer for the prevention of money laundering and terrorist
financing;
c) Obtain approval from senior management before entering into correspondent bank account relationship;
d) Document the respective responsibilities of the person engaged in financial or other business activities and of the credit
institution-customer; and,
e) With respect to payable-through accounts, it must be ensured that the credit institution-customer has verified the identity of its
customers, and performed ongoing due diligence on the customers having direct access to the correspondent bank accounts and
that it is able to provide relevant customers due diligence data to the correspondent institution, upon request.
A16. Yes.
A17. If the client is a non-Cypriot resident who is not seen face to face, then a professional adviser in the clients home country could be used to
confirm identity, or a copy of the passport authenticated by an attorney or consulate, or verification details covering true name, permanent
address & verification of signature could be checked with a reputable credit or financial institution or professional advisor in the prospective
clients home country.
Reporting
A18. Unit for Combating Money Laundering (MOKAS): http://www.law.gov.cy/law/mokas/mokas.nsf/dttindex_gr/dttindex_gr?OpenDocument

2010 989 SARs (MOKAS)

A20. According to 6.05 of the Directive, any knowledge or suspicion of money laundering or terrorist financing should be promptly reported to
MOKAS.
.
third countries, it is required to:
a) Gather sufficient information about the credit institution customer to understand fully the nature of the business and the activities
of the customer and to assess, from publicly available information, the reputation of the institution and the quality of its
supervision;
b) Assess the systems and procedures applied by the credit institution customer for the prevention of money laundering and terrorist
financing;

c) Obtain approval from senior management before entering into correspondent bank account relationship;
d) Document the respective responsibilities of the person engaged in financial or other business activities and of the credit
institution-customer; and,
e) With respect to payable-through accounts, it must be ensured that the credit institution-customer has verified the identity of its
Country by country comparison
customers, of high
and performed level due
ongoing Know Youron
diligence Customer andhaving
the customers Anti-Money Laundering
direct access information
to the correspondent bank accounts and
that it is able to provide relevant customers due diligence data to the correspondent institution, upon request.
Q16. Are
No,relationships with shell
because according banks specifically
to paragraph prohibited?
6.01 of the Directive for the Prevention & Suppression of Money Laundering & Terrorist Financing
A21. Laws of 2007 and 2010, the types of transactions which may be used by those exercising money laundering or terrorist financing are almost
unlimited, it is difficult to define a suspicious transaction.
Yes.
A16.
A22. According to the Law:

A17. If(27-(1))
the client
A is a non-Cypriot
person who resident who is not seen face to face, then a professional adviser in the clients home country could be used to
confirm (a)identity,
knowsorora reasonably
copy of the suspects
passport that
authenticated by an is
another person attorney
engagedor in
consulate,
launderingor or
verification
financingdetails covering
of terrorism true name,
offences, and permanent
address (b) & the
verification of signature
information on whichcould be checkedorwith
that knowledge a reputable
reasonable credit or
suspicion is financial institution
based, comes orattention
to his professional advisor
in the courseinofthe
hisprospective
trade,
clients home country. business or employment
profession,
shall commit an offence if he does not disclose the said information to the Unit as soon as is reasonably practicable after it comes to
his attention.
Reporting
27-(3) No criminal proceedings shall be brought against a person for the commission of the offences referred to in subsection (1), without
the expressed approval of the Attorney General.
Q18. To whom
27-(4) Anare Suspicious
offence Activity
under this Reports
section shall(SARs) made? by
be punishable Please include a not
imprisonment link exceeding
to their website.
five years or by a pecuniary penalty not exceeding
EUR5,000 or by both of these penalties.
A18. Unit for Combating Money Laundering (MOKAS): http://www.law.gov.cy/law/mokas/mokas.nsf/dttindex_gr/dttindex_gr?OpenDocument
A23. No. According to the Directive for the Prevention & Suppression of Money Laundering & Terrorist Financing Laws of 2007, paragraph 6.04,
a firm might also consider monitoring the types of transactions and circumstances that have given rise to suspicious transaction reports by
staff, with a view to updating internal instructions and guidelines from time to time. However there is no requirement to use automated
2010 989 SARs
Suspicious (MOKAS)
Transaction monitoring.
A24. According to paragraph 70 of the Law:
Persons engaged in financial and other business activities refrain from carrying out transactions which they know or suspect to be related
with money laundering or terrorist financing before they inform the Unit of their suspicion. It is provided that, if it is impossible to refrain from
carrying
Are thereout
anythe transaction
obligations or is likely
to report to frustrate
anything efforts
more than to pursuetransactions
suspicious the beneficiaries of a suspected
e.g. unusual money
transactions, laundering
cash or terrorist
transactions abovefinancing
a certain
Q20. operation,international
threshold, the persons wire
engaged in financial
transfers, or other business
other transactions etc.? activities, must inform the Unit immediately afterwards.
A20. According to 6.05 of the Directive, any knowledge or suspicion of money laundering or terrorist financing should be promptly reported to
Q25. MOKAS.
A25. Local legislation does not cover monitoring transactions outside Cyprus.
.
.
people who
of interest quality in
for the personal useassurance, tax and
of the reader, andadvisory
does notservices.
Youyoushould
and find
notout
act more
upon by
thevisiting us at
information
www.pwc.com.
on to the extent
matters permitted
law,does
advice. employees
upon
contained forthis
anypublication
consequences of you
without or anyone
advice.toNoact, in reliance onorthe
warranty contained
or implied)

any liability,
thisofpublication
separate decision
caretofor
refers
based on
independent
any
the consequences
network of member
it. entity.
legal
of firms
you or

Bosnia &
Bosnia & Herzegovina
Herzegovina
Key contact: Alma Ramezi Postal address: Fra Anela Last updated:
Key contact:
Email: Alma Ramezi
alma.ramezic@ba.pwc.com Postal address:
Zvizdovia Fra Anela
1, Tower B 13th Floor, Last updated:
January 2013
Email: alma.ramezic@ba.pwc.com
Tel: +387 33 295 235 Zvizdovia 1, Tower B 13th Floor,
71000, Sarajevo January 2013
Tel: +387 33 295 235 71000, Sarajevo
General
General
A1. 2009.
A1. 2009.
A2. Requirements of the previous AML legislation did not provide detailed guidelines for customer identification procedures, i.e. for PEPs
A2. Requirements of the Persons),
(Politically Exposed previous AML legislation
financial did not
institutions provide
which detailed
have guidelines
headquarters in afor customer
foreign identification
country, procedures,
non-face to i.e. for PEPs
face transactions. Also
(Politically Exposed Persons),
previous legislation financial
did not contain institutions
detailed which
guidance on have headquarters
the professional in a foreign
education country,
of those non-face
persons to face for
responsible transactions.
the systemAlso
for
previous
preventionlegislation
of money didlaundering.
not contain detailed guidance on the professional education of those persons responsible for the system for
prevention of money laundering.
Q3. Who
etc.).isPlease
the regulator
includefor
linkAML controls
A3. State Investigation and Protection Agency:
A3. State Investigation and Protection Agency:
http://www.sipa.gov.ba/en/onama.php
http://www.sipa.gov.ba/en/onama.php
Q4. Islocal
there any practical
Please provided
include to firms by
link to website, public
where authorities regarding AML requirements, beyond the FATF recommendations and
available.
A4. Yes - http://www.sipa.gov.ba/bs/kodeks/smjernicefoobo.pdf

A4. Yes - http://www.sipa.gov.ba/bs/kodeks/smjernicefoobo.pdf
A5. For customers who existed before the current AML legislation was introduced, companies are obliged to collect missing documentation and
A5. For customers who existed before the current AML legislation was introduced, companies are obliged to collect missing documentation and
data.
data.

A6. Yes.
A6. Yes.
Q7. Has the find
please country
a linkbeen
to a the subject
relevant of a (if
publicly available). Mutual Evaluation or IMF assessment exercise in the last 3 years? If yes,
A7. Yes - http://www.coe.int/t/dghl/monitoring/moneyval/Evaluations/round3/MONEYVAL(2009)42Rep_BIH3_en.pdf

A7. Yes - http://www.coe.int/t/dghl/monitoring/moneyval/Evaluations/round3/MONEYVAL(2009)42Rep_BIH3_en.pdf

Q8. Are there
If Yes, minimum
in place?
.
. This publication has been prepared for general guidance on matters of interest for the personal use of the reader, and does not constitute professional advice. You should not act upon the information
contained
This in thishas
publication publication withoutfor
been prepared obtaining
general specific
guidance professional
on matters advice. Thefor
of interest application
the personal anduse
impact of laws
of the canand
reader, vary widely
does not based on the
constitute specific facts
professional involved.
advice. No representation
You should not act uponorthewarranty (express
information
or implied)inisthis
contained given as to thewithout
publication accuracy or completeness
specific professional advice. contained in thisand
The application publication,
impact ofand,
lawstocan
thevary
extent permitted
widely basedby onlaw,
the PricewaterhouseCoopers
representation employees
or warranty and
(express
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given or the
as to assume any liability,
accuracy responsibility
or completeness or information
of the duty of carecontained
for any consequences of youand,
employees
2013 PwC.
publication
agents do not All rights
oraccept reserved.
for anyordecision Not
assumebased for further distribution without the permission of PwC. PwC refers to the network of member firms of PricewaterhouseCoopers International
on it. responsibility or duty of care for any consequences of you or anyone else acting, or refraining to act, in reliance on the information contained in this
any liability, Limited (PwCIL), or, as the
context requires,
or for individual member firms it.of the PwC network. Each member firm is a separate legal entity and does not act as agent of PwCIL or any other member firm. PwCIL does not provide any services
publication
2009 any decision

responsible
based All
acts or All
onrights
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reserved.
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separate
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firms offirms professional judgment or bind another member firm or PwCIL in any way.
member
A6. Yes.
Has the country been the subject of a FATF (or FATF-style) Mutual Evaluation or IMF assessment exercise in the last 3 years? If yes,
Know
Yes - http://www.coe.int/t/dghl/monitoring/moneyval/Evaluations/round3/MONEYVAL(2009)42Rep_BIH3_en.pdf
. A8. Transactions less than approximately EUR15,339 are not reported to Financial Reporting Organisation.
Q9. What
publication or for are thebased
any decision highonlevel
it. requirements for verification of customer identification information (individuals and legal entities)?
A9. Identification of the customer based on the documents, data and information obtained from relevant and objective resources (originals or

verified copies of ID cards, excerpt from court registers, etc) in order to:
a) Determine the beneficial owner;
b) Obtain information on the purposes and nature of the business relationship or transaction;
c) Perform continuous monitoring of business activities of the customers.
A10. Copies of identification documents must be verified.
A11. Identity of the beneficial owner of the legal entity is verified through the original or verified copy of the excerpt from court register or other
public register. If this is not possible the controller shall gather all relevant information from the original or verified documentation and
business records submitted by the agent of the beneficial owner.
A12. Reduced/simplified due diligence arrangements are available if customers are institutions with public authority (authorities of Bosnia and
Herzegovina, Federation Bosnia and Herzegovina, Republic of Srpska or Brcko District), banks, insurance companies and other physical
person or legal entity which is acting as agent in sale of insurance policies, investment and retirement funds regardless of the legal form
which have headquarters in BiH, or in the territory of European Union, or in the countries which fulfil internationally accepted standards for
prevention of money laundering and financing of the terrorist activities, based on the information obtained from Financial Reporting
organisation, international organisation or other authorised international authorities, and which are approved by Minister, and customers
which are characterised as low risk clients by controller.
A13. Enhanced customer due diligence measures are required for banks or other financial institutions which have headquarters abroad, politically
PEPs, in the event when customer was not present during the identification check, in other circumstances when, due to the business
relationship with, type of transaction, business profile of the customer or other circumstances is characterised as high risk.
A14. Enhanced customer procedure are required for foreign PEPs are required for every physical person who has or used to have exposed
public function, their close family members and close assistants: president of the state, premieres, ministers, deputies of ministers,
assistants of ministers, representatives of the legislators, judges of the supreme court, constitutional court or other courts, members of the
audit department and board of governor of the Central Bank, ambassadors and officers of the military forces, members of the management
or supervisory boards of the companies which are mainly owned by the state.
.
Questions and
customer procedure are required for foreign PEPs are required for every physical person who has or used to have exposed

public function, their close family members and close assistants: president of the state, premieres, ministers, deputies of ministers,
assistants of ministers, representatives of the legislators, judges of the supreme court, constitutional court or other courts, members of the
audit department and board of governor of the Central Bank, ambassadors and officers of the military forces, members of the management
or supervisory boards of the companies which are mainly owned by the state.
A15. Enhanced customer due diligence procedures are prescribed for banks and other financial institutions which have headquarters abroad.
Apart from identification and monitoring procedures, the company is obliged to:
a) gather information whether customer has approval, if yes for which period approval is granted, for providing banking services,
name and headquarter of the authority which issued the approval; description of the internal procedures which relate to
identification and prevention of money laundering and financing of the terrorist activities; description of the internal procedures for
identification of the beneficial owner of the customer, which relate to reports on suspicious transactions to the relevant authorities;
description of the internal procedures for keeping the reports, description of the internal controls and other procedures adopted by
the bank for detection and prevention of the money laundering or financing terrorist activities;
b) Description of the relevant legislation in the field of detection and prevention of money laundering and financing terrorist activities
in the state where bank or similar financial institution is established or registered;
. c) Written statement that bank or other similar financial institution does not have any business relation with shell banks;
d) prepared
Written forstatement
general guidance
thatonbankmatters
or ofother
interest for the personal
similar financial useinstitution
of the reader, and does
does not not
haveconstitute
legalprofessional
relationship advice.
withYou should
shell not act upon the information
banks;
or implied) is given ase)
to theWritten
accuracy statement
or completenessthat bank
of the or other
information similarin financial
contained institution
this publication, is extent
and, to the not under administrative
permitted supervision in
by law, PricewaterhouseCoopers theitsresidence
LLP, state and
members, employees and
agents do not accept or assumethat,any
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publication or for any decision based on it.which relate to detection and prevention of money laundering and financing of terrorist activities.
legislation
f)
2009 PricewaterhouseCoopers.Employee
All rightsofreserved.
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PricewaterhouseCoopers intotobusiness
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of foreign bank prior obtaining approval from his superior.
A16. Yes.
A17. The following identification procedures are required for customers not physically present during the identification process:
a) gather additional identification documents, data and information based on which the identity of the customer can be checked;
b) perform additional checks of the identification documents submitted and obtain confirmation for those documents from another
loan or financial institution; and
c) apply measures by which first payment is performed via an account opened in the name of customer in another financial
institution.
Reporting
A18. SARs reports are made to State Investigation and Protection Agency - http://www.sipa.gov.ba/en/onama.php .

2009 14.3 billion SARs

*
This results in a ratio of 1 SAR for every USD1.19 of GDP.
A20. No.
.
A16.

The following identification procedures are required for customers not physically present during the identification process:
A17.
a)
gather additional identification documents, data and information based on which the identity of the customer can be checked;
b)
perform additional checks of the identification documents submitted and obtain confirmation for those documents from another
loan or financial institution; and
Country by country
c) applycomparison
measures by ofwhichhigh
firstlevel Know
payment Your Customer
is performed andopened
via an account Anti-Money Laundering
in the name of customerinformation
in another financial
institution.
Reporting
A21. Transactions below approximately EUR15,339.
A18. SARs reports are made to State Investigation and Protection Agency - http://www.sipa.gov.ba/en/onama.php .
A22. AML legislation prescribes financial penalties for non compliance with reporting requirements for legal entity, controller, responsible person
in the legal entity and independent entrepreneur.
2009 14.3 billion SARs
A23. No.
*
This results in a ratio of 1 SAR for every USD1.19 of GDP.
A24. A transaction which is identified as suspicious is temporary suspended based on the warrant of the Financial Reporting organisation up to a
maximum of 5 days.
A20. No.
Local legislation allows the Financial Reporting Organisation to request documentation and information from other authorities which are
A25. responsible for prevention of money laundering.
.
people who
does not services.
You and find
should not out
act more
upon by
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information
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Belgium
Key contact: Rudy Hoskens Postal address: Last updated:
Email: rudy.hoskens@be.pwc.com Woluwe Garden; Woluwedal 18; B-1932 Sint- January 2013
Tel: +32 2 710 4307 Stevens-Woluwe; Belgium
General
A1. The local law became effective in 1993. However, to incorporate the third AML Directive, it has been amended by the law of 18 January
2010.
A2. N/A
A3. Since 1 April 2011, the supervision of the Belgian financial sector has been organised according to the Twin Peaks model, with two
autonomous supervisors, namely the National Bank of Belgium (NBB) and the Financial Services and Markets Authority (FSMA), both of
which are competent (depending on the licence, NBB or FSMA is competent) in the field of AML related matters to the financial sector.
http://www.nbb.be http://www.fsma.be
A4. There is specific guidance per sector on the website of the Belgian Financial Intelligence Processing Unit (CTIF-CFI) for a risk-based
approach. http://www.ctif-cfi.be/website/index.php?option=com_content&view=article&id=71&Itemid=99&lang=en
A5. No - however, the local law requires identification data to be updated in cases where there are doubts about the veracity or accuracy of
previously obtained identification data or where the risk sensitivity of the client requires this.
Moreover , the amendment by law on 18 January 2010, which implied a broader application field, obliges, in its transitional provisions, the
institutions and persons to:
a) identify and verify the place and date of birth of natural persons with whom they have a business relationship on 05 February
2010 (i.e. date of entry into force of the amending law) within a period that is to be determined depending on the risk, but no later
than 05 February 2015;
b) update, depending on the risk, the identification of the beneficial owners of the customers with whom they have a business
relationship on 05 February 2010 ; this period is extended to five years for the identification of the date of birth and place of birth;
c) take adequate and specific risk based measures to identify Politically Exposed Persons (PEPs) (see Q 14) and to apply the
specific measures on preventing the use of the financial system for purposes of money laundering and terrorist financing and the
Code on Companies by 05 February 2011 at the latest.
A6. Before the amendment of the local law by the law of 18 January 2010, the Banking Finance and Insurance Commission (CBFA - local
supervisor) already recommended a risk based approach for financial institutions and insurance companies (providing life insurance
services) in its circular guidelines (PPB 2005/5 jo. PPB 2004/8 and D.258 jo. D.250). With the amendment by the law of 18 January 2010, a
risk based approach is implemented in local law in relation to specific topics.
.
2013 PwC.
accept reserved.
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consequences refers
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A7. After the adoption of their Mutual Evaluation Report (MER), FATF member countries are required to provide information on the measures
that have been implemented to deal with the deficiencies identified in the report. Belgium is subject to this process of providing a biennial
update (i.e. every two years) to the FATF Plenary on any of the 40+9 Recommendations that are rated PC (Partially Compliant) or NC (Non
Compliant). The second update was provided to the Plenary in June 2009 is available at:
www.ctif-cfi.be/website/index.php?option=com_content&view=article&id=56&Itemid=75&lang=en
There has been no IMF assessment during the last three years.
A8. Yes - when the customer wishes to carry out a transaction outside the context of a business relationship:
a) for an amount below EUR10,000;
b) consisting in a transfer of funds to a payees account within Belgium for an amount of less than or equal to EUR1,000 on condition
that:
a. the transfer is a payment within the terms of an agreement for the provision of goods or services, concluded between
the payer and the payee;
b. the payees account was opened to enable the payment for the provision of goods or services;
c. the payment service provider of the payee is subject to the obligations set out in the AML laws; and
d. this payment service provider is able, by means of a unique identifier, to trace the transaction via the payee back to the
payer.
c) concerns banks and financial institutions.
The above exceptions cannot apply where there is a suspicion of money laundering or terrorist financing or when there are doubts about the
veracity or accuracy of previously obtained identification data regarding a customer who has already been identified.
A9. Individuals and institutions must identify clients and their agents.
Identification of natural persons: surname, first name, date and place of birth and, whenever possible, relevant information on the
address of the identified person.
Identification for legal persons, trusts, fiduciaries and similar legal arrangements: corporate name, registered office and directors,
and note must be taken of the provisions regarding the power to commit the legal person, trust, fiduciary or similar legal arrangement.
The identification must be verified by means of a supporting document, of which a copy is made on paper or by electronic means. For
natural persons, a copy of their identity card or passport is required and for legal person, a copy of their coordinated statutes.
Together with the identification, information must be collected regarding the purpose and intended nature of the business relationship.
A10. Clients must be identified by means of a supporting document, of which a copy is made on paper or by electronic means. Such documents
need to be probative documents, admissible as evidence. There is no information about certification by external third parties in local
legislation.
A11. For the beneficial owner, the identification must cover the surname, first name and, whenever possible, the date and place of birth. In
addition, whenever possible, relevant information must be collected with regard to address details. Furthermore, appropriate risk based
measures must be taken to verify these data sources. Beneficiaries of a life insurance contract must be identified before the actual
remittance. The regulation therefore foresees the possibility of postponed identification.
.
A12. The local regulation does foresee this possibility where:

a) the customer or beneficial owner is a credit or financial institution as defined in art. 2 of the third AML Directive, established in
Belgium or another country within the EEA, or an equivalent institution established in a third country that has foreseen
requirements and controls similar to those in the third AML Directive and of which a specific list is to be drawn in a Royal Decree;
b) the customer or beneficial owner is a listed company whose securities are admitted to trading on the regulated market within the
meaning of Directive 2004/39/EC in a country of the EEA, or is a listed company from a third country, designated in a Royal
Decree, and which is subject to disclosure requirements consistent with community legislation ;
c) the beneficial owner of a pooled account held by notaries and other independent legal professionals established in Belgium or
another country within the EEA or from third countries , designated in a Royal Decree, provided that they are subject to
requirements to combat money laundering or terrorist financing consistent with international standards and are supervised for
compliance with those requirements and provided that the information on the identity of the beneficial owner is available, on
request, to the institutions that act as depository institutions for the pooled accounts. If the client would be bound by professional
secrecy, and thus unable to provide the information on the identity of the beneficial owner, the client needs to confirm in writing or
by electronic means to the depository institution that the beneficial owners of the pooled accounts involved are solely clients with
whom the relationship consists in ascertaining their legal position or performing their task of defending or representing those clients
in, or concerning judicial proceedings including giving advice on instituting or avoiding proceedings. the client or beneficial owner is
a Belgian public authority ;
d) the client is a European public authority or institution, included on a list to be drawn in a Royal Decree;
e) the client is a person or institution indicated in a specific list yet to be drawn in a Royal Decree;
In addition, by way of derogation, it is allowed not to apply customer or beneficial owner due diligence in respect of:
a) life insurance policies where the annual premium is no more than EUR1,000 or the single premium is no more than EUR2,500;
b) insurance policies for pension schemes if there is no surrender clause and the policy cannot be used as collateral;
c) a pension, superannuation or similar scheme that provides retirement benefits to employees, where contributions are made by way
of deduction from wages and the scheme rules do not permit the assignment of a members interest under the scheme;
d) electronic money as defined in article 3, 1, 7 of the law of 22 March 1993 regarding the pursuit of and prudential supervision of
credit institutions, where, if the device cannot be recharged, the maximum amount stored in the device is no more than EUR150, or
where, if the device can be recharged, a limit of EUR2,500 is imposed on the total amount transacted in a calendar year, except
when an amount of EUR1,000 or more is redeemed in the same calendar year by the bearer as referred to in article 5 of the law of
22 March 1993;
e) in respect of any other product or transaction representing a low risk of money laundering or terrorist financing which meets the
criteria to be established in a royal decree.
A13. Local regulation foresees enhanced customer due diligence measures on a risk sensitive basis in situations which by their nature can
represent a higher risk of money laundering or terrorist financing, and at least in the following situations:
a) establishing a business relationship with or carrying out a transaction for a customer that was not physically present for
identification purposes (non face-to-face contact);
b) establishing a business relationship or carrying out a transaction with or for a PEP (see Q14 below);
c) engaging in cross-border correspondent banking relationships with respondent institutions from third countries (see Q15 below);
A14. Belgium has instituted a comprehensive set of measures applicable to PEPs. These measures include:
a) applying appropriate risk based procedures to determine whether the customer or his beneficial owner is a PEP;
b) obtaining approval from a sufficiently senior level of management before establishing business relations with such customers;
c) taking appropriate risk-based measures to establish the source of wealth and funds that are involved in the business relationship or
transaction;
d) conducting enhanced ongoing monitoring of the business relationship.
A15. Belgium is in full compliance with the FATF recommendations regarding issues of correspondent banking. It is obliged to:
a) gather sufficient information about the respondent institution in question to fully understand the nature of its business and to
determine from publicly available information its reputation and the quality of the supervision to which it is subjected to;
b) assess the respondent institutions anti-money laundering and anti-terrorist financing controls;
c) obtain approval from a sufficiently senior level of management before establishing new relationships;
d) document in writing the respective responsibilities of each institution;
e) with respect to payable-through accounts, be satisfied that the respondent institution has verified the identity of and has performed
ongoing due diligence on the customers having direct access to accounts of the correspondent and that it is able to provide
. relevant customer due diligence data to the correspondent institution, upon request.
Q16. Are
publication or for anyrelationships with
decision based on it. shell banks specifically prohibited?
A16. Yes.
A15. Belgium is in full compliance with the FATF recommendations regarding issues of correspondent banking. It is obliged to:
a) gather sufficient information about the respondent institution in question to fully understand the nature of its business and to
determine from publicly available information its reputation and the quality of the supervision to which it is subjected to;
b) assess the respondent institutions anti-money laundering and anti-terrorist financing controls;
c) obtain approval from a sufficiently senior level of management before establishing new relationships;

d) document in writing the respective responsibilities of each institution;
e) with respect to payable-through accounts, be satisfied that the respondent institution has verified the identity of and has performed
ongoing due diligence on the customers having direct access to accounts of the correspondent and that it is able to provide
relevant customer due diligence data to the correspondent institution, upon request.
A16. Yes.
A17. When entering into a business relationship with a client that is not physically present, specific and adequate measures need to be taken to
deal with the increased risk of money laundering and terrorism financing that exist in such circumstances.
Reporting
A18. The Belgian Financial Intelligence Processing Unit (CTIF-CFI), established by the Law of 11 January 1993, is a central part of the Belgian
AML/CFT system. CTIF-CFI is an independent administrative authority with legal personality and is supervised by the Ministers of Justice
and Finance. CTIF-CFI is in charge of processing suspicious financial facts and transactions linked to money laundering and terrorism
financing and are reported by institutions and individuals specified in the law. URL: http://www.ctif-cfi.be/

2011 20,001 SARs

The key figures of the statistics of CTIF-CFIs activities in 2011 point to a continuous increase in the number of disclosures received and
processed in accordance with the Law of 11 January 1993 on preventing use of the financial system for purposes of money laundering and
terrorist financing.
A20. Article 14 1: The institutions and persons as referred to in Articles 2 1, 3 and 4 of the law, shall carefully examine any transaction or
action they consider particularly likely, by its nature or its unusual character in view of the customers activities, by the circumstantial
elements or by the capacity of the persons involved, to be related to money laundering or terrorist financing.
The following institutions and persons should report the following transactions:
a) Credit institutions and financial institutions referred to in article 2,1: if the information provided about the payer of the transaction
is insufficient, and if there is suspicion of the proliferation of mass destruction weapons concerning the restrictive measures
* GDP at purchaser's pricestowards
is the sum Iran
of grossand Korea
value added(ECby allREG
resident1781/2006, ECeconomy
producers in the REG 423/2007,
plus any product ECtaxes
REG and329/2007).
minus any subsidies not included in the value of the products. It is
calculated without making
b) deductions
Real Estate for depreciation of fabricated
agents must oblige assets or for depletion
regarding and degradation
restrictions on cash of natural resources.
payments Data are
(article in current
20-21) The U.S. dollars.
sale priceDollar figuresproperty
of real for GDP are
may converted from
only be
paid
alternative conversion factor is used.by means of a bank transfer or cheque, unless the amount does not exceed 10% of the sale price and as long as this amount
. is not higher than EUR15.000. Where the persons referred to in articles 2, 1, 19 and 3, 1 of the law, discover that the above
This publication has been prepared
provisionfor general
has guidance
not been on matters of interestthey
respected, for theshall
personal use of the reader,
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constitute professional
Intelligence advice. You should notUnit
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agents do not accept or assumeArticle 21: The
any liability, price of ora duty
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or anyone whose
else acting, total value
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equalonorthegreater than
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contained in this may
notbased on it. in cash, regardless of whether the sale takes place in a single or in several apparently related transactions.
be paid
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ofofdoubt about the veracity or accuracy of previously obtained
been identified (discretionary), in case of a suspicion of money-laundering or
terrorism financing, in case of international transactions related to persons or companies registered in a state with insufficient or
contra productive legislation with regards to anti money laundering and terrorism financing and finally in case of the suspicion of
serious and organised fiscal fraud.
A21. See A20, restrictions on cash payments: cash transactions below EUR15,000.
According to article 40 of the AML law of 1993, non compliance with reporting requirements towards CTIF-CFI (articles 20 and articles 23 to
is not higher
ongoing than EUR15.000.
due diligence Wherehaving
on the customers the persons referredtotoaccounts
direct access in articles
of 2,
the1, 19 and 3, 1and
correspondent of the
that law, discover
it is able that the above
to provide
provision
relevant has not
customer duebeen respected,
diligence data tothey shall immediately
the correspondent informupon
institution, the Financial
request. Intelligence Processing Unit in writing or by
electronic means.
Article 21: The price of a sale by a merchant of one or more products whose total value is equal or greater than EUR15.000 may
not be with
Are relationships paidshell
in cash, regardless
banks of whether
specifically the sale takes place in a single or in several apparently related transactions.
prohibited?
Q16.
Questions and Answers:c) all the companies and persons referred to in article 2, 1: in case of doubt about the veracity or accuracy of previously obtained

identification data about a customer who has already been identified (discretionary), in case of a suspicion of money-laundering or
A16. Yes. terrorism financing, in case of international transactions related to persons or companies registered in a state with insufficient or
contra productive legislation with regards to anti money laundering and terrorism financing and finally in case of the suspicion of
serious and organised fiscal fraud.
A17. When entering

Are there into a business
any de-minimis relationship
thresholds belowwith a client
which that is not
transactions do physically
not need topresent, specific and adequate measures need to be taken to
be reported?
Q21. deal with the increased risk of money laundering and terrorism financing that exist in such circumstances.
A21. See A20, restrictions on cash payments: cash transactions below EUR15,000.
Reporting
A22. According
28) Belgian
to article 40 of the AML law of 1993, non compliance with reporting requirements towards CTIF-CFI (articles 20 and articles 23 to
can result in the Intelligence
following sanctions imposed by the competent authority: 1) publication of adopted
A18. The Financial Processing Unit (CTIF-CFI), established by the Law of 11 January 1993, is measures andofdecisions,
a central part the Belgian2)
Imposing system.
AML/CFT an administrative
CTIF-CFI is fine
anofindependent
not less than EUR250 and
administrative not more
authority withthan
legalEUR1.25 million.
personality and isThe CTIF-CFIbyshall
supervised be informed
the Ministers by the
of Justice
competent
and authority
Finance. CTIF-CFIof the final
is in sanction
charge imposed. suspicious financial facts and transactions linked to money laundering and terrorism
of processing
financing and are reported by institutions and individuals specified in the law. URL: http://www.ctif-cfi.be/
A23. According to article 32 of the regulation of the National Bank of Belgium, the secondary review system is required to react very efficiently
and rapidly.
Volume As a consequence, only an automated system could fulfil these requirements. Nevertheless, the Commission could accept the
of SARs:
A19. use of
2011 a non automated
20,001 SARs system, if the institution can prove that, considering the nature and the volume of the transactions, it is possible to
conduct the necessary monitoring without an automated system.
A23. According
The to article
key figures 23 statistics
of the of the law,ofthe CTIF-CFIactivities
CTIF-CFIs may, should it deem
in 2011 pointsuch
to aaction necessary
continuous due to
increase in the
the seriousness or urgency received
number of disclosures of the matter,
and
oppose execution
processed of any with
in accordance suspected
the Lawtransaction of which
of 11 January 1993iton
has been informed.
preventing use of The CTIF-CFI
the financial shall determine
system to which
for purposes transactions
of money and
laundering andto
which accounts
terrorist financing.the opposition shall apply and shall inform the institutions and persons referred to in article 2, 1 immediately. This
opposition shall halt the execution of the transaction for a maximum of two working days starting from the time of notification. If the CTIF-
CFI thinks the measure should be extended, it shall refer the matter to the Public Prosecutor, who will take the necessary decisions. In the
absence of a decision within the abovementioned two days after notification, the said institutions and persons are free to execute the
transaction.
A25. There is no specific restriction to monitor the transactions in another jurisdiction but the responsibility remains within the entity in Belgium. In
particular, transactions of some branches of foreign banks are monitored by the parent company.
.
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www.pwc.com.
Austria
Key contact: Andrej Psorn / Roland Schobel Postal address: Last updated:
Email: Andrej.Psorn@at.pwc.com / Erdbergstrasse 200; January 2013
Roland.Schoebel@at.pwc.com 1030 Vienna; Austria
Tel: +43-1-501 88-2995/+43-1-501 88-1170
General
A1. 1994.
Current AML / CFT relevant amendments:
a) Austrian Banking Act and Austrian Insurance Supervision Act last amended on 01 July 2010;
b) Austrian Criminal Code ( 165 following StGB) last amended on 01 July 2010;
c) Austrian Finance Criminal Code ( 38a and 39 FinStrG) last amended on 01 January 2011;
A2. N/A - The Austrian AML laws and regulations are now based on the Third EU Anti Money Laundering Directive.
A3. a) Austrian Financial Markets Authority (FMA) http://www.fma.gv.at/de/startseite.html

b) Austrian Financial Markets Authority (FMA) http://www.fma.gv.at/de/startseite.html
c) Relevant economic chamber http://portal.wko.at/wk/startseite.wk
A4. There are six different circulars in place regarding AML / CFT regulations for banking industry, other financial services and insurance
companies, issued by the Austrian Financial Markets Authority, last amended on 24/04/2012.
http://www.fma.gv.at/de/rechtliche-grundlagen/rundschreiben/geldwaescherei-terrorismusfinanzierung.html
A5. Yes - every active customer has to be identified as well as every client whose account has been closed since 1994.
A6. Yes - a circular on the risk-based approach was published by the Austrian Financial Markets Authority on 23 December 2009, updated on 1
December 2011:
http://www.fma.gv.at/typo3conf/ext/dam_download/secure.php?u=0&file=5912&t=1326279853&hash=c176490f3237d72c36f7a4e59bd1aa8
e
A7. Yes, FATF Mutual Evaluation Report Austria as of 26 June 2009 http://www.fatf-gafi.org/dataoecd/22/50/44146250.pdf
Executive Summary: http://www.fatf-gafi.org/dataoecd/33/28/44168301.pdf
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A8. Yes - one-off transactions below EUR15,000, if there is no AML or CFT suspicion.
A9. Identification and verification is performed using official ID e.g. passport. Customers have to inform the institution if they act on their own
account, or on a principal's account. If someone acts on behalf of another person (as a trustee), the identity of that person (the trustor) must
also be clarified. The customer has to disclose the ultimate beneficial owner. The institution has to recheck the identity of the ultimate
beneficial owner using a risk based approach.
Individuals: the following has to be obtained:

a) full name;
b) date and place of birth;
c) nationality;
d) address; and
e) signature.
As part of the verification process, the identity of the customer has to be verified by an independent source (documents of identification),
e.g. a passport, identity card or an Austrian driving licence. The name of the state authority which issued the document and the date of
issuance also have to be recorded.
Legal entities: the following has to be obtained:

a) registered name and domicile of the entity; and
b) full name of the legal representatives of the entity.
This data has to be verified by appropriate documentation e.g. an excerpt of the company register.
A10. The requirements are defined and are to be seen as a way to rely on the authenticity of the document if there are any doubts and the
identity of a person should be verified by other measures. In this case, a suspicious activity report has to be considered.
A11. The Austrian banking and insurance laws require the verification of the identity of beneficial owners holding more than 25% of the shares or
voting rights of an entity or holding 25% or more of a trust or foundation. Where a principal owner is another corporate entity or trust, the
institution has to take measures to establish the identity of the ultimate beneficial owners (who can only be natural persons) and/or, if
applicable, the trustors. In case of a trust or foundation, the identity of the founder and the beneficiaries designated to receive 25% or more
of the trust/foundation have to be disclosed by the client.
Credit institutions, financial institutions and insurance companies must call upon the customer to reveal the identity of the customer's
beneficial owner(s). The customer must comply with this request, and credit institutions, financial institutions and insurance companies must
take risk-based and appropriate measures to verify the beneficial owner's identity so that the credit institution, financial institution or
insurance company is satisfied that it knows who the beneficial owner is. In the case of legal persons or trusts, this also includes taking risk-
based and appropriate measures in order to understand the ownership and control structure of the customer.
A12. Reduced due diligence arrangements are available for the following, but only if the AML/CFT risk is considered low:
a) domestic public authorities and public authorities of the European Union (EU);
b) listed companies;
c) credit and financial institutions situated in a third country which impose requirements equivalent to those defined in the third EU
AML Directive and which are supervised in compliance with those requirements; and
d) beneficial owners of pooled accounts held by notaries and other legal professionals from EU Member States.
.
A13. For customers where a higher risk of money laundering or terrorist financing applies, for example:
a) if the customer has not been physically present for identification (distance business/non-face-to-face-relationships);
b) for cross-frontier correspondent banking relationships with correspondent banks from other countries or from the European
Economic Area (EEA) (the latter only if the AML/CFT risk is considered heightened); and
c) for Politically Exposed Persons (PEPs) of other EU Member States and of third countries.
Furthermore, if the client or an authorised signatory, a person, to whom the client has a significant business relationship, or the trustor or the
beneficial owner has his/her domicile or residence in one of the following states (see below), or the transaction is made via an account at a
bank in one of the following states:
a) Iran
b) Democratic Peoples Republic of Korea (DPRK)
c) Bolivia
d) Cuba
e) Ethiopia
f) Indonesia
g) Kenya
h) Myanmar
i) Nigeria
j) Pakistan
k) Sao Tome and Principe
l) Sri Lanka
m) Syria
n) Tanzania
o) Thailand
p) Turkey
q) Vietnam
r) Yemen
A14. In any transaction or business relationship with a PEP of another EU Member State (except Austria) or another country.
A15. Enhanced due diligence procedures to be performed for cross-border correspondent banking relationships with correspondent banks
from third countries or from the EEA (the latter only if the AML/CFT risk is considered heightened) as follows:
a) credit institutions and financial institutions must gather sufficient information about a correspondent bank to fully understand the
nature of its business and be able to ascertain the reputation of the institution and the quality of supervision on the basis of
publicly available information;
b) credit institutions and financial institutions must satisfy themselves of the correspondent bank's anti-money laundering and anti-
terrorist financing controls;
c) credit institutions and financial institutions must obtain approval from senior management before establishing new correspondent
banking relationships;
d) credit institutions and financial institutions must document the respective responsibilities of each institution; and
e) with respect to payable-through accounts, credit institutions and financial institutions must be satisfied that the correspondent
bank has verified the identity of and performed ongoing due diligence on the customers having direct access to accounts of the
correspondent, and that it is able to provide relevant customer due diligence data to the correspondent bank upon request.
A16. Yes - credit institutions are prohibited from entering into or continuing a correspondent banking relationship with a shell bank. Credit
institutions have to take appropriate measures to ensure that they do not engage in or continue correspondent banking relationships with a
bank that is known for permitting its accounts to be used by a shell bank.
A17. Non face-to-face relationships and transactions are considered heightened AML/CFT risk by the relevant Austrian AML laws and
regulations. For this reason, additional due diligence is always required for non face-to-face relationships and transactions.
Trustees must always be identified personally (obligation of personal presence) - non face-to-face relationships are not sufficient for
. purposes of identification of trustees.
Furthermore,
or implied) is given additional
as to the accuracy due diligence
or completeness is always
of the information required
contained in this(whether
publication, face-to-face
and, to the extentorpermitted
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by law, PricewaterhouseCoopers doubts, indication
its members, or and
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suspicion
agents do not accept of money
or assume laundering
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responsibility financing.
duty of care In these cases,
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anyone else acting, reportstohave
or refraining act, in to be considered.
reliance on the information contained in this
Reporting
Questions and
purposes Answers:
of identification of trustees.

Furthermore, additional due diligence is always required (whether face-to-face or non face-to-face) in case of any doubts, indication or
suspicion of money laundering or terrorist financing. In these cases, suspicious activity reports have to be considered.
Reporting
purposes of identification of trustees.
Furthermore, additional due diligence is always required (whether face-to-face or non face-to-face) in case of any doubts, indication or
suspicion
Suspiciousof activity
money reports
laundering or be
are to terrorist financing.
reported In these Financial
to the Austrian cases, suspicious activity
Intelligence Unit reports
(A-FIU),have to be Geldwschemeldestelle.
so called considered.
A18. http://www.bmi.gv.at/cms/BK/meldestellen/geldwaesche/start.aspx
Reporting
A19. Volume
To whomofare
SARs:
Suspicious Activity Reports (SARs) made? Please include a link to their website.
Q18. 2011 2,115 SARs
A18. Suspicious activity reports are to be reported to the Austrian Financial Intelligence Unit (A-FIU), so called Geldwschemeldestelle.
http://www.bmi.gv.at/cms/BK/meldestellen/geldwaesche/start.aspx

Q20. Are there

Volume of any obligations to report anything more than suspicious transactions e.g. unusual transactions, cash transactions above a certain
SARs:
A19. threshold,
2011 international
2,115 SARs wire transfers, other transactions etc.?

A20. Suspicious
2011 activities million
USD417,656 regarding moneydata.worldbank.org
(Source: laundering and terrorist
*
) financing as well as the suspicion that a client might not properly have
disclosed a trusteeship have to be reported.
threshold,
No, every international wire transfers,
suspicion described othertotransactions
in A20 has be reported,etc.?
regardless of the amount.
A21.
A20. Suspicious activities regarding money laundering and terrorist financing as well as the suspicion that a client might not properly have
disclosed
Are there aany
trusteeship
penaltieshave to be
for non reported. with reporting requirements e.g. tipping off?
compliance
Q22.
A22. No specific penalties prevail for non compliance with reporting requirements, but there are penalties for non compliance with AML and CFT
Q21. regulations
Are (e.g.
there any 99 (2) BWG,
de-minimis Austrian
thresholds belowBanking Act). Non compliance
which transactions withtoreporting
do not need requirements can be seen as non compliance with
be reported?
AML and CFT regulations.
A21. No, every suspicion described in A20 has to be reported, regardless of the amount.
A23. No, there is no legal or regulatory requirement to use specific AML/CFT IT systems, but in practice, larger institutions will not be able to
apply the risk based approach without any IT monitoring technology.
A22. No specific penalties prevail for non compliance with reporting requirements, but there are penalties for non compliance with AML and CFT
regulations (e.g. 99 (2) BWG, Austrian Banking Act). Non compliance with reporting requirements can be seen as non compliance with
AML and CFT regulations.
A24. In the
Are course
there any of suspicious activity
requirements (legal orreporting, thetoinstitution
regulatory) should Suspicious
use automated ask the A-FIU, whether monitoring
Transaction it can proceed with the transaction or not. The A-
technology?
Q23. FIU has the right to stop ongoing transactions or to forbid future transactions, if there is a suspicion.
A23. No, there

* GDP at purchaser's pricesisisno
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Q25. Does the

alternative conversion factorlocal legislation allow transactions to be monitored outside the jurisdiction?
is used.
.
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clearobtaining
A25.
Q24. There
Is thereisano requirement rule intospecific
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place, but thereadvice.
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in
Austria also in jurisdictions outside Austria where they conduct business (e.g. in CEE Central and Eastern Europe - and SEE South
Eastern
publication or for Europe-
any decision based countries
on it. where banks with headquarters in Austria also conduct business).
.
www.pwc.com.
the information refers to thewithout
contained in this publication networkobtaining
of member firms professional
specific of

advice. No representation or warranty (express or implied) is given as
United Arab Emirates

Key contact: Ashruff Jamall / Usman Butt Postal address: Last updated:
Email: ashruff.jamall@ae.pwc.com / DIFC, 4th Floor; Building 5; The Exchange; January 2013
usman.s.butt@ae.pwc.com Dubai
Tel: +971 4 304 3105 / +971 4 304 3094
General
A1. With effect from 2000, the Central Bank of UAE issued the initial AML regulations under Circular 24/2000 (the regulations). The DFSA
AML Rulebook (AML Rules) became effective from 2004 onwards.
A2. N/A
A3. The regulator for AML controls in respect of UAE is the UAE Central Bank (CBUAE) and in respect of the Dubai International Financial
Centre (DIFC) free-zone, it is the Dubai Financial Services Authority (DFSA). The CBUAE licenses and regulates all banks and financial
institutions operating in the United Arab Emirates. The DFSA is the regulator of authorised firms, including banks, insurance companies,
investment banks, asset managers and fund administrators, providing financial services in the DIFC.
The links to the respective websites are as follows:

http://www.centralbank.ae/en/index.php?option=com_content&view=article&id=75&Itemid=95
http://www.dfsa.ae/Pages/DoingBusinesswithDFSA/BeingSupervised/Anti-MoneyLaundering/Anti_MoneyLaundering.aspx
A4. There is no such practical guidance provided.
A5. An addendum to the UAE Central Bank regulations (the addendum) states that where accounts have been opened prior to the year 2000,
customer due diligence procedures must be undertaken to ensure that there are no risks in continuing such relationships.
A6. The UAE authorities do not appear to apply a risk based approach to the application of the preventive measures, and no sectors have been
specifically exempted from the provisions under the AML/CFT legislation and regulations. In addition, the UAE Central Bank regulations
have not been structured so as to recognise the possibility of a risk-based approach to the implementation of the preventive measures at an
institutional level.
This is in contrast to the approach adopted by the Dubai Financial Services Authority (DFSA), which applies an overriding principle that
institutions should have systems and controls that recognise and mitigate their specific risks. The DFSA requires institutions to apply a risk
based approach to customer due diligence and ongoing monitoring of accounts. The guidance within the rules specifies the need to
undertake a risk assessment of its customers, and to apply a level of identification and verification that is commensurate with the risk.
.
2013 PwC.
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A6. The UAE authorities do not appear to apply a risk based approach to the application of the preventive measures, and no sectors have been
specifically exempted from the provisions under the AML/CFT legislation and regulations. In addition, the UAE Central Bank regulations
have not been structured so as to recognise the possibility of a risk-based approach to the implementation of the preventive measures at an
institutional level.
This is in contrast to the approach adopted by the Dubai Financial Services Authority (DFSA), which applies an overriding principle that
institutions should have systems and controls that recognise and mitigate their specific risks. The DFSA requires institutions to apply a risk
based approach to customer due diligence and ongoing monitoring of accounts. The guidance within the rules specifies the need to
undertake a risk assessment of its customers, and to apply a level of identification and verification that is commensurate with the risk.
.A7. The country had been subject to the mutual evaluation by IMF followed by a discussion with the MENAFATF and FATF in 2008. The report
can be accessed via the below given link:
http://www.menafatf.org/TopicList.asp?cType=train

A8. Yes - payment of cash for transfers and drafts above AED2,000 (USD544) for money changers and AED3,500 (USD 952) for banks, and
also for receipt of transfers and drafts above AED40,000 (USD10,884) to be paid in cash or in the form of travellers cheques. A circular
issued by the UAE Ministry of Economy and Commerce sets out thresholds for insurance transactions.
A9. Banks and financial institutions: The regulations require a bank to obtain full identification details of customers wishing to open a bank
account, including full name of the account holder, current address, place of work, evidence of physical verification of the individual's
passport including retention of a copy, trade licences in respect of judicial persons, name and addresses of shareholders whose
shareholding in public companies exceed 5% and, in respect of societies, original certificates issued by the Ministry of Labour and Social
Affairs. Information for transactions exceeding a certain limit is also included.
Individuals: The standard customer identification information specified in the regulations includes the name, address and place of work. In
the case of natural persons, institutions are required to check the applicant's passport and retain a copy, which must be annotated by the
account officer as a true copy. Passports are considered a universal and reliable form of verification in the UAE.
Corporates: The regulations specify that the institution must take the name and address of the entity and, in the case of a partnership, must
record similar information for each of the partners. In addition, it must "obtain all information and documents with regard to juridical persons",
but specifies, in particular, the government-issued trade licence required by all businesses registered in the UAE. Institutions have typically
interpreted "all documents" to mean the Memorandum and Articles of Association (or equivalent) and any documents that support the legal
status of the company to conduct business in the jurisdiction.
The AML Rules require all entities to establish and verify the identity of the customers. In addition to the above requirements for individuals
and corporate, the AML Rules require information regarding nature of business to be conducted, origin of funds and source of wealth or
income. There is further guidance available for corporate entities (subject to certain exemption) such as annual report and list of main
shareholders holding more than 5% of the issued capital.
A10. For individuals, a copy of the passport, and for corporates, a copy of the trade licence, stamped and initialled by the concerned employee as
"a true copy of the original" is required. There is no information in the regulations or guidance issued by the CBUAE as to whether copies
can be certified by external third parties such as notaries, lawyers and accountants.
However, the AML Rules provide guidance for the identification documents to be certified as true copy by the specified authorities such as
registered lawyer, notary, chartered accountant, government ministry, post office, police officer, embassy or consulate.
A11. The addendum states that, when opening accounts or remitting money, banks or financial institutions must obtain satisfactory evidence of
the identities of the beneficial owners of companies and businesses and clearly understand the ownership and control structure of all legal
entities.
In addition to the above, the regulations state that, when opening an account for a public shareholding company, a bank must obtain the
name and address of the shareholders with holdings of 5% or more.
The AML Rules require establishing and verifying the identity of the beneficial owners and obtaining sufficient and satisfactory evidences of
their identities. In addition, the AML Rules state that all corporate entities (subject to certain exemptions) should obtain a list of main
shareholders holding more than 5% of the issued capital.

.
A11. The addendum states that, when opening accounts or remitting money, banks or financial institutions must obtain satisfactory evidence of
the identities of the beneficial owners of companies and businesses and clearly understand the ownership and control structure of all legal
entities.
Questions and
In addition to theAnswers:
above, the regulations state that, when opening an account for a public shareholding company, a bank must obtain the
name and address of the shareholders with holdings of 5% or more.

The AML Rules require establishing and verifying the identity of the beneficial owners and obtaining sufficient and satisfactory evidences of
their identities. In addition, the AML Rules state that all corporate entities (subject to certain exemptions) should obtain a list of main
Country by country holding
shareholders comparison
more thanof 5%
high level
of the Know
issued Your Customer and Anti-Money Laundering information
capital.

.
A12.
This publicationThe
has one exception
been prepared
forpublication
contained in this banks (AED
by theguidance
for general
without 40,000
obtaining or
CBUAE on for simplified
matters
AEDprofessional
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of interestdue
3,500 advice.
see A8) Theand
diligence
for the
money
application
relates
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of the reader,
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and does notfalling
2,000).
can vary
below
constitute the cash
professional transaction
advice. thresholds
You should not act upon the specified
information
widely based on the specific facts involved. No representation or warranty (express
The
publication or for anyAML Rules
decision basedprovide
on it. for an exception to the customer identification requirements where the customer is: (1) another authorised firm; (2)
an ancillary services provider; (3) an authorised market institution; or (4) a credit institution or other financial institution, which is subject to
regulation,
PricewaterhouseCoopers including
International anti-money
Limited, laundering,
each of which byand
is a separate a financial
independentservices
legal entity.regulator in a FATF
country or another relevant authority in a FATF
country.
A13. The addendum states that enhanced due diligence processes should be applied with respect to high risk customers which includes foreign
Politically Exposed Persons ('PEPs'), correspondent banks and specific businesses and individuals dealing in precious metals and stones,
real estate, luxury goods, auction houses, private banking customers and non-resident account holders.
In addition to the above, the indicators provided in Articles 8 to 14 of the regulations make reference to certain high risk scenarios (e.g.
customers from drug producing countries or from countries that do not adequately apply the FATF standards), that should be considered as
at higher risk of money laundering.
The AML Rules require enhanced due diligence measures for higher risk products, services and customers, such as non face-to-face
business relationships or transactions, internet based products, correspondent banking relationships and PEPs. In particular, enhanced due
diligence measures are required for customers from higher risk countries, as specified under/by: (1) the FATF findings; (2) the consolidated
list of financial sanctions in the European Union Office and HM Treasury (United Kingdom) lists; and/or (3) the Office of Foreign Assets
Control (OFAC) of the United States Department of Treasury.
Appropriate use must also be made of the United Nations Security Councils relevant resolutions and sanctions.
A14. The addendum requires banks and financial institutions to have systems and controls in place to identify whether a potential or existing
customer or a beneficial owner is a foreign PEP. Banks and financial institutions are required to obtain written approval from senior
management to open accounts for a foreign PEP.
The AML Rules require detailed KYC investigations at the beginning of a relationship and on an ongoing basis where the business
relationship involves a PEP and family members or close associates of PEPs. Detailed monitoring and due diligence procedures include
analysis of complex structures, appropriate measures for establishing the source of wealth, developing a profile of expected activity, senior
management approval and regular oversight of the relationship by the senior management.
A15. The addendum and the AML Rules require banks, exchange houses and other financial institutions to carry out due diligence measures
when entering into a cross-border correspondent banking relationship. In addition, research must be conducted from publicly available
information on the correspondent bank's business activities, their reputation and the quality of supervision and whether the institution has
been subject to any regulatory action. Senior management written approval is required to be obtained prior to such relationships being
established.
A16. The addendum and the AML Rules strictly prohibit any relationship, directly or indirectly, with institutions that have no physical presence
(shell banks and companies).
A17. Article 3.1 of the regulations requires institutions to take possession of the passport at the time of opening an account. This is understood by
institutions (and reinforced by the UAE Central Bank) to mean that the process must be completed in the presence of the customer and that
non-face-to-face account opening is not permitted in any circumstances.
Investors in securities can place their orders through a broker by telephone or in person, but the majority of orders are currently placed by
telephone. Trading on the Dubai Financial Market (DFM) and Abu Dhabi Securities Market (ADSM) occurs on an electronic trading system,
which automatically lists, matches, and executes trades. Securities brokers in the UAE provide investors with direct access to several
trading platforms. There are no specific requirements in the AML rules that seek to address the risks posed in this area.
. The AML Rules require firms to take specific and adequate measures necessary to compensate for the higher risk of money laundering,
which might arise from non face-to-face business relationships or transactions such as via email, telephone or internet.
Reporting
non-face-to-face account opening is not permitted in any circumstances.
Investors in securities can place their orders through a broker by telephone or in person, but the majority of orders are currently placed by
telephone. Trading on the Dubai Financial Market (DFM) and Abu Dhabi Securities Market (ADSM) occurs on an electronic trading system,
which automatically lists, matches, and executes trades. Securities brokers in the UAE provide investors with direct access to several
trading platforms. There are no specific requirements in the AML rules that seek to address the risks posed in this area.

The AML Rules require firms to take specific and adequate measures necessary to compensate for the higher risk of money laundering,
which might arise from non face-to-face business relationships or transactions such as via email, telephone or internet.
Reporting
A18. The Suspicious Transactions Reports (STRs) are required to be reported to the Anti-Money Laundering and Suspicious Cases Unit
(AMLSCU) of the UAE Central Bank and a copy to the DFSA (for entities regulated by the DFSA). Refer to the link below.
http://www.dfsa.ae/Pages/DoingBusinesswithDFSA/BeingSupervised/Anti-MoneyLaundering/STR.aspx
A20. Yes, UAE Central Bank and the DFSA stipulate an obligation to report unusual transactions. Fines are imposed in case of non-compliance
of these requirements.
A21. As per the regulation 26/1/2002 issued by the Central Bank regarding declaration when importing cash money into the UAE, any amount not
exceeding AED40,000 (USD10,884) can be brought into the country without declaration.
A22. Yes, Article 16 of UAE Federal Law No 4 of 2002 sets out the penalties for failure to report any act related to Money Laundering offence.
A23. There is no such mandatory requirement for use of automated monitoring technology.
A24. In case a transaction is identified as suspicious, the AMLSCU of the UAE Central Bank shall give instructions to the institutions on how to
proceed with the transaction. In this case, the customer in question expresses his wish to proceed with the transaction before the institution
receives the instruction from the AMLSCU, the institution shall immediately contact the AMLSCU for further instructions.
.
A25. There is no specific guidance on monitoring transactions outside UAE. However, Article 21 and 22 of Federal Law No 4 of 2002 issued by
the CBUAE permits cooperation with countries with which the UAE has a ratified treaty.
www.pwc.com.
Qatar
Key contact: Akrum Shawky Postal address: Last updated:
Email: akrum.shawky@qa.pwc.com 41st Floor Tornado Tower, West Bay, Doha, January 2013
Tel: +974 66710877 State of Qatar, P.O. Box 6689
General
A1. 2002.
A2. N/A.
A3. The Qatar Financial Centre Regulatory Authority (www.qfcra.com) and The Qatar Central Bank (www.qcb.gov.qa ).
A4. Yes. The QFCRA has a rulebook giving practical AML/CFT guidance to firms within its jurisdiction.
http://www.complinet.com/net_file_store/new_rulebooks/q/f/QFCRA_6883.pdf
A5. No.
A6. Yes.
A7. Yes- www.imf.org/external/pubs/ft/scr/2008/cr08322.pdf .
A8. No.
.
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A9. With regards to identification requirements for individuals and legal entities, authorised firms should:
.
a) verify the identity of any customer with or for whom the authorised firm acts or proposes to act;
b) establish
contained in this publication whether
without obtaining the
specific customer
professional is acting
advice. for himself
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and impact the behalf
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accuracy or completeness sufficient
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contained evidence
in this publication, and,of all extent
to the of their identities.
permitted by law,In cases where the customer
PricewaterhouseCoopers is acting
LLP, its members, on and
employees
behalf of another person, the authorised firm must obtain a written statement from that person.
If it is necessary to enter into an insurance contract before the identification requirements
can be completed, the authorised firm must have
controls to ensure that any money received is not passed on to any person until the customer identification requirements have been fulfilled.

If the customer does not supply evidence of identity in a manner that permits the authorised firm to comply with the Qatar Financial Center
('QFC') AML/CFT regulations, the authorised firm must:
a) discontinue any activity it is conducting for him; and
b) bring to an end any understanding it has reached with him - unless in either case the authorised firm has informed the regulatory
authority.
If at any time the authorised firm becomes aware that it lacks sufficient customer identification information/documentation, or develops a
concern about the accuracy of its current information/documentation, it must promptly obtain appropriate material to verify the customers
identity.
A10. Copies must be verified against the original document. If the original document is not available, a certified copy of such document must be
presented for verification. Certification can be done by any of the following: a registered lawyer, a registered notary, a chartered accountant,
a government ministry, a post office, a police officer or an embassy or consulate.
A11. Beneficial ownership is defined as:

a) the natural person(s) who own(s) or control(s) directly/indirectly 10% or more of the shares of a legal person, not being a company
listed on an official stock exchange;
b) the natural person(s) who directly/indirectly is beneficiary to 10% or more of the property of a legal person or trust, not being a
company listed on an official stock exchange; or
c) the natural person(s) on whose behalf a transaction or activity is being conducted.
The authorised firm is expected to establish to its satisfaction the true identity of a customer and any other person on whose behalf the
customer is acting, including that of the beneficial owner of the relevant funds which may be the subject of a transaction to be considered. It
also should obtain evidence of verification that is sufficient to establish that the person is indeed who he/she claims to be. Where the
principal owner is another corporate entity or trust, there is a requirement to look behind that company or trust and to verify the identity of
the ultimate beneficial owner or settlor. The capacity of the signatories to act on behalf of the club or society and the identity of beneficial
owners of the funds should be established and verified.
A12. Simplified due diligence arrangements apply in the following cases:

a) a relevant person is not required to establish the identity of a customer for the AML Regulations if the customer is an authorised
firm or another relevant person; and
b) a relevant person is not required to establish the beneficial ownership of a person or any relevant funds for the AML Regulations if
the relevant persons customer is an authorised firm or another relevant person.
The exceptions above do not apply if the relevant person knows or suspects, or has reasonable grounds to know or suspect, that a
customer or a person on whose behalf the customer is acting is engaged in money laundering.
A13. The authorised firm must assess its risks in relation to money laundering and perform enhanced due diligence investigations on higher risk
products, services and customers having regard to guidance issued by the regulatory authority.
.
the relevant persons customer is an authorised firm or another relevant person.
The exceptions above do not apply if the relevant person knows or suspects, or has reasonable grounds to know or suspect, that a
customer or a person on whose behalf the customer is acting is engaged in money laundering.

Know
Q13.
In what circumstances are enhanced customer due diligence measures required?
The authorised firm must assess its risks in relation to money laundering and perform enhanced due diligence investigations on higher risk
A13.
Country by country
products, comparison
services of high
and customers level
having Know
regard Your Customer
to guidance and
issued by the Anti-Money
regulatory authority.Laundering information
A14. The authorised firm must implement and maintain detailed monitoring and due diligence procedures for each customer who is, or becomes
a PEP. The monitoring and due diligence procedures must include:
a) analysis of any complex structures used by the customer (for example, structures involving trusts or multiple jurisdictions);
. b) measures to establish the origin of funds and the source of wealth or income:
i. for
thegeneral guidance onthat
requirement matters of interest
senior for the personal
management use of thebe
approval reader, and does
obtained not constitute
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You account
should not with
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or completeness of the information contained in this publication, and, to the extent permitted by law, PricewaterhouseCoopers LLP, its members, employees and
agents do not accept or assumeii. any liability,
if an account hasor been
responsibility duty of opened,
care for anyto engage inofany
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or anyone else acting, customer;
or refraining to act, in reliance on the information contained in this
publication or for any c)
decision based on it.
development of a profile of expected activities for the customer relationship to provide a basis for transaction and account
monitoring;
All rights and
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regular oversight
reserved. PricewaterhouseCoopers refers to the network of member firms of
Limited, eachofofthe
which is a separate and
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A15. The authorised firm that establishes, operates or maintains a correspondent account for a correspondent banking client must ensure that it
has arrangements to:
a) conduct due diligence at the opening of an account for a correspondent banking client including measures to identify its ownership
and management structure, major business activities and customer base, location and the intended purpose of the correspondent
account;
b) ensure that the correspondent banking client has verified the identity of and performs ongoing due diligence on those customers
who have direct access to the correspondent account, and that the correspondent banking client is able to provide customer due
diligence information upon request to the authorised firm; and
c) monitor transactions processed through such account, in order to detect and report any suspicion of money laundering.
The authorised firm must not:

a) establish a correspondent banking relationship with a shell bank;
b) establish or keep anonymous accounts or accounts in false names; or
c) maintain a nominee account which is held in the name of one person, but controlled by or held for the benefit of another person
whose identity has not been disclosed to the authorised firm.
A16. Yes.
Reporting
A18. Qatar Financial Information Unit (www.qfiu.gov.qa)
A19. Information on the volume of SARs reported is not publicly available.
A20. The regulations require firms to report where they have reasonable grounds to know of or suspect that the funds are the proceeds of
criminal conduct or terrorist activities.
.
A19. Information on the volume of SARs reported is not publicly available.
Questions
Q20. Are thereand Answers:

A20. The regulations require firms to report where they have reasonable grounds to know of or suspect that the funds are the proceeds of
criminal
Country by conduct
country or terrorist activities.
comparison of high level Know Your Customer and Anti-Money Laundering information
.
A21. The regulation does not give a minimum or maximum threshold, but rather expresses the obligation of the firm to report where there are
reasonable for general
grounds guidance
to know on suspect
of or matters of interest
that thefor funds
the personal
are use
theofproceeds
the reader, and does not constitute
of criminal conductprofessional
or terroristadvice. You should not act upon the information
activities.
A22. In the event of non compliance with the reporting requirements, Article 44 of the Qatar Law shall apply:
A supervisory authority, in case of a violation of the obligations established under this law by a financial institution, NPO, or DNFP, made
intentionally or by gross negligence, is evidenced, may impose one or more of the following measures and sanctions:
a) requesting regular reports on measures it is undertaking;
b) requesting compliance with specific instructions;
c) sending written warnings;
d) replacing or restricting the powers of managers, board members, or controlling owners, including the appointing of an ad hoc
administrator;
e) barring individuals from employment within a business, profession or activity, either permanently or for a provisional period;
f) imposing supervision, suspending license, restricting or withdrawing any other form of permission and prohibiting the continuation
of a business, profession or activity;
g) imposing financial penalty in an amount no greater than QAR10m.
h) any other measures.
The supervisory authority shall inform the Unit of the measures and sanctions imposed.
A23. The Qatari and QFC law requires firms to have systems in place to enable them to monitor all complex, unusual, large transactions, or
unusual patterns of transactions, that have no apparent or visible economic or lawful purpose. The firm must examine as far as possible the
background and purpose of all complex, unusual large transactions and make a record of its findings.
A24. It is not mentioned expressly in the Law or in the QFC Regulations whether a firm is allowed to proceed with the legal advice/transaction in
the event that a suspicious transaction report has been filed.
A25. While the Law or QFC Regulations do not expressly state that transactions should be monitored outside the jurisdiction, it does stipulate that
a firm must conduct enhanced customer due diligence measures and enhanced ongoing monitoring for customers from high risk
jurisdictions whose line of business is more vulnerable to corruption.
www.pwc.com.
professional advice.professional advice. or
No representation You should (express
warranty not act upon the information
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Oman
Key contact: Asad Moqueem Postal address: Last updated:
Email: asad.moqueem@om.pwc.com Hatat House, Suites 205-210, January 2013
Tel: +968 24559110 Wadi Adai, Muscat, Oman
General
A1. The first AML law in Oman Law of Money Laundering was issued through a Royal Decree No. 34/2002 and published in the Official
Gazette No. 716 dated 1 April 2002. The law was notified by CBO circular BM 936 dated 7 April 2002.
Executive regulations for the law were issued in 2004 through Royal Decree No.72/2004.
Royal Decree 79/2010 issued on 28 June 2010 promulgated Law of Combating Money Laundering and Terrorism Financing. The earlier law
is still effective until the time the Executive Regulation under the new law will be issued.
A2. N/A.
A3. Central Bank of Oman (CBO) is the primary regulator for AML controls for Banking and other financial institutions (http://www.cbo-
oman.org/).
The Financial Intelligence Unit (FIU), an independent unit under Royal Oman Police and Capital Market Authority, is also the regulator for
AML controls (http://www.fiu.gov.om/, http://www.cma.gov.om/english/pages/default.aspx).
A4. Practical guidance in the form of the Manual of Suspicious Transactions Reports is available on the website of FIU-ROP.
(http://www.fiu.gov.om/files/English.pdf ).
A5. No
A6. The executive regulations describe transactions that may pose a potential threat for money laundering. These follow a risk based approach
by focusing on customers and transactions that pose a larger money laundering threat to financial institutions.
A7. FATF evaluation in 2011 (http://www.fatf-gafi.org/dataoecd/13/28/48503164.pdf).
.
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A6. The executive regulations describe transactions that may pose a potential threat for money laundering. These follow a risk based approach
by focusing on customers and transactions that pose a larger money laundering threat to financial institutions.
Questions and been

Q7. Has the country Answers:

A7. FATF evaluation in 2011 (http://www.fatf-gafi.org/dataoecd/13/28/48503164.pdf).

.
A8.
contained in thisThe regulations
publication do not specific
without obtaining defineprofessional
any suchadvice.threshold. However,
The application each ofcompany/bank,
and impact laws can vary widelyasbased
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involved. its own threshold.
No representation or warranty (express

2009 PricewaterhouseCoopers. level
All rights requirements
reserved. for verification
PricewaterhouseCoopers of to
refers customer
the networkidentification
of member firms information
of

A9. Individuals:
a) customer name (as per identity card, resident card and passport);
b) nationality;
c) identification documents e.g. residence card/labour card, passport etc.; and
d) detailed information on the customer relating to i) postal address and ii) work address.
Corporate customers:
a) Articles of Association;
b) copies of identification of authorised signatories;
c) verification of signatures of authorised signatories through independent sources;
d) Ministry of Commerce & Industry certificates; and
e) other identification documents as deemed necessary.
A10. There is no compulsory requirement with regard to independent verification.
A11. The high level requirements for beneficial ownership are similar to those required for any customer.
A12. PEP, NRI & privileged customers are high risk clients and exposed to high due diligence as compared to normal individuals.
Each customer is subject to similar customer due diligence requirements.
A13. High risk customers and suspicious transactions require enhanced due diligence.
A14. Additional due diligence is always required. For PEPs, approval is required from senior management.
A15. AML questionnaire developed by each bank is sent to the correspondent bank before entering into relationship. Licenses are requested and
efforts are made to ensure they are not shell companies.
A16. Yes.
.
A15. AML questionnaire developed by each bank is sent to the correspondent bank before entering into relationship. Licenses are requested and
efforts are made to ensure they are not shell companies.
Know
A16. by
Country Yes.
A17. Non face-to-face transactions are avoided in most cases. Enhanced due diligence is always required for such relationships.
.
Reporting
Q18. To whomInternational
PricewaterhouseCoopers are Suspicious Activity
Limited, each Reports
of which (SARs)
is a separate made? Please
and independent include a link to
legal entity. their website.
A18. SARs are reported directly to FIU-ROP Financial Intelligence Unit - Royal Oman Police.
Website: http://www.fiu.gov.om/

2011 209 SARs (FIU-ROP)
2010 103 SARs (FIU-ROP)
A20. No however, FIU-ROP can investigate any transaction based on its discretion.
A21. No.
A22. Non-compliance in relation to AML regulation may result in a penalty from CBO. FIU-ROP can also investigate the case and impose a
penalty.
A23. AML regulations require companies to use AML software.
A24. No.
A25. No.
www.pwc.com.
This publication has been prepared for general the information
guidance contained
on matters in thisfor
of interest publication
the personalwithout
use ofobtaining specific
the reader, professional
and does advice.
not constitute No representation
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Lebanon
Key contact: Camille C. Sifri Postal address: Last updated:
Email: camille.sifri@lb.pwc.com Saba House bldg, Block B & C, Said Freiha January 2013
Tel: +961 (5) 428600 Street, Hazmieh, Lebanon
General
A1. 2001
A2. N/A
A3. Banks and financial institutions are regulated by the Central Bank of Lebanon (www.bdl.gov.lb) and in 2001, an independent, legal entity
with judicial status was established, independent of the authority of the Central Bank of Lebanon to investigate money laundering
operations, and to monitor compliance with the rules and procedures stipulated by this Law.
As for non financial sector, there is no defined regulator. Banks are required to monitor these clients closely and identify any potential
suspicious transactions.
A4. Practical guidance is provided by circular no. 83 published by the Central Bank of Lebanon (http://www.bdl.gov.lb/circ/circpdf/83.pdf) and by
circulars issued by the Special Investigation (http://www.sic.gov.lb). And it should be noted that periodically the Central Bank of Lebanon
issues intermediary circulars, updating the basic circular and adding new requirements.
A5. Yes. As stipulated by circular no.83, all banks and financial institutions are required to launch a KYC process.
A6. Yes.
A7. Lebanon was subject to a Mutual Evaluation conducted by the MENA (Middle East and North Africa) FATF. The report was issued in
November 2009. The link to the report is as follows: http://www.menafatf.org/MER/MutualEvaluationReportoftheLebaneseRepublic-
English.pdf.
.
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A8. No due diligence is required for all transactions below US$ 10,000 or equivalent. However, it should be noted that any new client opening an
account in any bank is required to submit a detailed KYC form.
A9. Individuals: a copy of a passport or identity card and KYC form showing residential/work addresses, profession and average
income/month.
Legal entities: a copy of the following documents:

a) articles of incorporation
b) certificate of registration at the Chamber of Commerce
c) the identity card of those charged to sign in the name of the entity and
d) copy of the latest financial statements.
A10. Copies should be compared to original source documents and should be certified by notaries, if necessary.
A11. The customer should fill out a form showing the identity of the beneficial owner (name, family name, place of residence, profession and
information about his financial situation).
A12. There are specific criteria where performing due diligence on transactions above USD10,000 can be avoided, especially in the case of cash
businesses. These exemptions should be approved by a special committee established within the bank to combat money laundering
activities.
A13. Additional due diligence measures are required if customers are classified as high risk as per the Central Bank's guidelines.
A14. Central Bank of Lebanon stipulates that all banks should conduct an elevated due diligence effort on all politically exposed clients and to be
classified as High Risk.
A15. Before establishing a relationship with a correspondent bank, the Bank should check the following:
a) the correspondent bank is not a shell bank;
b) it actually exists based on submitted documentary evidence;
c) it does not deal with shell banks;
d) it has a good reputation and is subject to effective controls; and
. e) it implements sufficient and effective procedures to fight money laundering and terrorist financing.
A16. Yes.
A15. Before establishing a relationship with a correspondent bank, the Bank should check the following:
a) the correspondent bank is not a shell bank;
b) it actually exists based on submitted documentary evidence;

c)
d)
e)
it does not deal with shell banks;
it has a good reputation and is subject to effective controls; and
it implements sufficient and effective procedures to fight money laundering and terrorist financing.
A16. Yes.
A17. Transactions in writing: The Bank should verify the client's identity and the authenticity of the signature.
Transactions done via an agent: The Bank should obtain an official procuration and the identity cards of the agent and the client.
Reporting
A18. The Bank should report suspicious activities to the Governor of the Central Bank in his capacity as chairman of the Special Investigation
Commission (SIC). The link is as follows: http://www.sic.gov.lb.

2010 357 SARs

2011 USD40,956 million (expected) - Source: data.worldbank.org*
A20. No unless it is specifically requested by the Central Bank of Lebanon.
A21. No. All suspicious transactions, regardless of materiality, need to be reported.
A22. Any person who does not comply with the reporting requirements could be imprisoned and subject to a fine in accordance with Law number
318.
.
Questions and
A19. Volume of SARs:Answers:

2010 357 SARs

2011 USD40,956 million (expected) - Source: data.worldbank.org*
A23.
Q20. As stipulated
Are there any by circular 83,
obligations
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A20. No unless it is specifically requested by the Central Bank of Lebanon.

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Are Bankany
should inform the
de-minimis SIC of suspicious
thresholds transactions
below which anddo
transactions could process
not need thereported?
to be transactions unless requested by the SIC. However if the
client account was frozen at the request of the Central Bank of Lebanon, banks are not allowed to process any transaction unless they get
the approval of the Central Bank of Lebanon. In addition, suspicious accounts cannot be closed before consulting with the SIC.
A21. No. All suspicious transactions, regardless of materiality, need to be reported.
A25. The branches of Lebanese banks operating abroad must, as a minimum, adopt the procedures mentioned in these Regulations. In case this
proves to bewho
impossible
A22. Any person does notdue to thewith
comply Regulations incompatibility
the reporting requirementswith the mandatory
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Jordan
Key contact: Fadi Fakhouri Postal address: Last updated:
Email: fadi.fakhouri@jo.pwc.com PricewaterhouseCoopers 'Jordan' January 2013
Tel: +962 (6) 500 1300 Third Circle, Jabal Amman, 14 Hazza' Al-
Majali Street, PO Box 5175, Amman 11183,
Jordan
General
A1. The date when the regulations became effective is different from one industry to another and is written at the top of each of the attachments
for the different industries listed at the following link:
http://www.amlu.gov.jo/Public/English.aspx?Lang=2&Page_Id=3401&Menu_Parent_ID=49&type=R
A2. The unit of Anti Money Laundering and Counter Terrorist Financing in Jordan has been established in 2007. No previous regime existed.
A3. Anti Money Laundering and Counter Terrorist Financing Unit in Jordan is the regulator for most of these institutions except for the banking
AML regulations and the Money Exchange Companies which were regulated by the Central Bank of Jordan as well as the Insurance
Commission Anti Money Laundering Regulations which were issued by the Board of Directors of the Insurance Commission.
The Anti Money Laundering for the securities activities are also governed by the Securities Law in Jordan
http://www.amlu.gov.jo/public/Main_english.aspx?Lang=2&Site_Id=1&Page_Id=1936&M=1
A4. Yes - please refer to the following links:

Law - http://www.amlu.gov.jo/Public/English.aspx?Lang=2&Page_Id=2721&Menu_Parent_ID=49&type=R
Regulations - http://www.amlu.gov.jo/Public/English.aspx?Lang=2&Page_Id=3047&Menu_Parent_ID=49&type=R
Instructions and Guidelines - http://www.amlu.gov.jo/Public/English.aspx?Lang=2&Page_Id=3401&Menu_Parent_ID=49&type=R
Instructions Issued Pursuant to the Law and Regulations -
A5. No.
A6. Not clear in the legislation.
Q7. Has the country been the subject of a FATF (or FATF-style) Mutual Evaluation or IMF assessment exercise since 2003? If yes, please find a
A7. Information on whether the country has been subject to any FATF (Financial Action Task Force) assessment is not publicly available.

If isYes,
to clients. PwCIL what areorthe
not responsible liablevarious thresholds
for the acts or omissionsinofplace?
any of its member firms nor can it control the exercise of their professional judgment or bind them in any way. No member firm is
A6. Not clear in the legislation.
Has the country been the subject of a FATF (or FATF-style) Mutual Evaluation or IMF assessment exercise since 2003? If yes, please find a
Q7. link to a relevant report (if publicly available).
Know
Information on whether the country has been subject to any FATF (Financial Action Task Force) assessment is not publicly available.
A8. Yes, in the banking regulations attached at

The bank shall exert due diligence with relation to occasional customers in the following cases:
a) If the value of a transaction or a number of transactions that seem to be related exceed (JOD10,000) or are unusual transactions;
b) Cash transactions exceeding JOD20,000 or its equivalent in foreign currencies. Also cash transactions which are less than this
threshold but where there is evidence that they are related shall be considered as one transaction.
Article 6:Transfers
First: Scope of Application
1- Provisions of this article shall apply to electronic transfers above JOD700 or its equivalent in foreign currencies.
A8. Yes, in the banking regulations attached at
The bank shall exert due diligence with relation to occasional customers in the following cases:
a) If the value of a transaction or a number of transactions that seem to be related exceed (JOD10,000) or are unusual transactions;
b) Cash transactions exceeding JOD20,000 or its equivalent in foreign currencies. Also cash transactions which are less than this
threshold but where there is evidence that they are related shall be considered as one transaction.

Article 6:Transfers
First: Scope of Application
1- Provisions of this article shall apply to electronic transfers above JOD700 or its equivalent in foreign currencies.
A9. For the Banking Industry:

Procedures for identifying and verifying the identity of the customer:
a) The bank shall set the proper systems to ensure the identification and verification of the customers identity in accordance with
the requirements stated.
b) The bank shall preview the official identification documents of the customer and shall obtain a copy of the same documents
signed by a competent employee declaring that it is an original copy.
c) The bank shall take the necessary procedures to verify the validity of the information and data obtained from the customer from
reliable and neutral sources, including contacting the competent entities that issued such official documents, and refer to the
database of the Civil Status which is available to the banks and the website of the Companies Control Department.
d) Procedures for identifying the identity of a natural person shall take into consideration the following:
a. The identification data shall include the full name of the customer, nationality, permanent address, phone number, work
address, type of activity, purpose of business relationship and its intended nature, names and nationalities of persons
authorised to manage the account and any information the bank deems necessary.
b. With regard to legally unqualified persons, such as minors, documents of their legal representatives who manage such
accounts shall be obtained.
c. In case a person deals with the bank on behalf of the customer, a notarized power of attorney or a bank authorisation shall be
obtained and kept, or a copy of the same in addition to verifying the identity of the proxy according to the procedures for
identifying and verifying the identity of the customer stipulated in these instructions.
Procedures for identifying the identity of a legal person shall take into consideration the following:
a) Identity data shall include the name of the legal person, legal status, name of owners and their shares, the authorised signatories,
domicile of the legal person, line of business, capital, registration date and number, tax number, national identity number of the
organisation, names and nationalities of signatories authorised to run the account, phone numbers, purpose of the business
relationship and its nature so the bank is aware of the ownership structure and the provisions governing the powers to take
binding decisions for the legal person and any information the bank deems necessary.
b) The existence, legal form, names of the owners and the authorised signatories of the legal person shall be verified by virtue of
necessary documents and information contained therein, such as, memorandum and articles of association, and the certificates
issued by the Ministry of Industry and Trade and certificates issued by the commercial and industrial chambers in addition to
obtaining the required official certificate from the competent authority in case the company is registered abroad.
c) Obtain the required documents indicating an authorisation by the legal person to natural persons to run the account as well as the
identity of the authorised persons according to the procedures for identifying and the identity of the customer stipulated in these
instructions.
d) Public shareholding companies are excluded from the data request for names of owners and their shares, and for them it is
sufficient to obtain a list of shareholders whose shares exceed 10% of the capital.
Insurance:
b) The company shall view the official documents to identify the customer and their activities, and to have a copy of this
documentation signed by the competent company employee or authorised person to declare that it is an original copy.
c) The company shall take the necessary procedures to verify the validity of the information and data obtained from the customer
using neutral and reliable sources, including contacting the competent entities that issued the official documents, and referring to
the website of the Companies Control Department.
d) Procedures for identifying the identity and the activity of a natural person shall take into consideration the following:
a. The data of identification shall include the full name of the customer, nationality, date and place of birth, national number for
Jordanian people and the passport number for non Jordanian people, current permanent residence address, purpose of the
business relationship and its nature and any other information the company considers necessary.
b. Regarding persons with incomplete or without mental capacity, the company shall have the documents related to them and to
the persons who represent them legally, as the case may be, according the provisions of item a) of this paragraph.
c. In case a person deals with the company on behalf of the customer, the necessary official documents for authorising this
person shall be obtained and kept, or a copy of the same in addition to verifying the identity and the activities of the customer
and person who deal with the company on behalf of the customer, according to the provisions of item a) of this paragraph.
e) Procedures for identifying the identity and the activities of a legal person shall take into consideration the following:
a. Identity data shall include the name of the legal person, legal status, location address, type of activity, capital, date and
number of registration with the competent entities including tax number, phone numbers, purpose of the business relationship
and its nature, names and addresses of owners and their shares, the authorised signatories, binding authority of the legal
person or legal arrangement so that the company is aware of the ownership structure and the provisions governing the powers
to take binding decisions for the legal person, and any other information the company deems necessary.
b. Verify the existence of the legal person and its legal form, as well as the names of owners and signatories of the legal person
through the necessary documents and the information they include, such as Memorandum of Association, Articles of
Association, and certificates issued by the Ministry of Industry and Trade, Chambers of Industry and Trade and Companies
Control Department, in addition to the necessity to obtain a registration certificate of the legal person at the competent
authorities in case the company is registered outside the kingdom.
c. Obtain the required documents indicating an authorization by the legal person to the natural persons to represent it, the nature
of their relation with the legal person, and identify their identity and their activities according to the procedures of identifying the
identity and the activities of the customer mentioned in item c) a. above. The company shall be sure that there is no legal
preventive that prevents transacting with them and obtain their signatures.
For other industries please refer to the attached documents at the following links:
c. Obtain the required documents indicating an authorization by the legal person to the natural persons to represent it, the nature
of their relation with the legal person, and identify their identity and their activities according to the procedures of identifying the
identity and the activities of the customer mentioned in item c) a. above. The company shall be sure that there is no legal
preventive that prevents transacting with them and obtain their signatures.
Questions
For otherand Answers:
industries please refer to the attached documents at the following links:

A10. No additional requirements other than those mentioned above in Q9.
A11. Banks:
Identity data shall include the name of the legal person, legal status, name of owners and their shares, the authorised signatories, domicile
of the legal person, line of business, capital, registration date and number, tax number, national identity number of the organisation, names
and nationalities of signatories authorised to run the account, phone numbers, purpose of the business relationship and its nature, and so
the bank is aware of the ownership structure and the provisions governing the powers to take binding decisions for the legal person and any
other information the bank deems necessary.
In case the beneficial owner is a legal person, reasonable procedures shall be taken to verify the ownership structure and the controlling
management of the legal person. This includes relying on data or information obtained from official documents and data to get the
contentedness about the identity of the beneficiary owner.
Insurance:
Procedures for identifying the identity of the beneficial owner shall take into consideration the following:
a) Taking appropriate procedures for verifying the identity of the beneficial owner and this include viewing data and information
obtained from official documents and data until the company is satisfied that it knows who the Beneficial Owner is.
b) Requesting the customer to submit a written declaration to specify the identity of the beneficial owner. Such declaration shall
contain at least the identification data of the customer identity.
c) Obtaining information about provisions regulating the business of the legal person including its ownership structure and the
controlling management of it.
For other industries please refer to the attached documents in the email. However the two major areas are for banks and insurance
industries.
A12. For Banks:
Simplified customer due diligence procedures:

a) The Central Bank of Jordan has the right to determine the transactions or customers who may be subject to simplified customer
due diligence procedures when identifying and verifying the identity of the customer and the beneficiary owner, this should be
limited by international standards, recommendations and best practices which decides examples of customers or transactions of
low risks and any international controls or local requirements in this respect.
b) Simplified customer due diligence procedures are prohibited whenever there is suspicions of money laundering or terrorist
financing transactions, or whenever high risk circumstances occur.
Insurance:
The company may simplify the procedures of identifying and verifying the customer, his activity and the Beneficial Owner in the following
cases:
a) Dealing with financial institutions which are subject to certain procedures for anti-money laundering and counter terrorist financing
similar to the procedures mentioned in these Instructions and the Decisions issued by virtue thereof, including FATF
recommendations, where implementation is subject to supervision.
b) Dealing with public shareholding companies that are subject to regulatory disclosure requirements.
c) Dealing with ministries and government departments and institutions.
d) Dealing with customers residing in another country if such country is sufficiently applying the international standards for anti
money laundering and counter terrorist financing, including the FATF recommendations.
e) Insurance policies for pension schemes if the policy cannot be used as collateral and there is no surrender clause.
f) Life insurance policies where the annual premium is no more than JOD1,000 or a single premium of no more than JOD2,000.
g) General insurance business which single premium or total annual premiums do not exceed the amount of JOD3,000.
For purposes of applying the provisions of paragraph (A) of the Article in the link below, simplified procedures for identifying the customer
and his activity shall include the following:-
a) The customer shall submit a document with the required data pursuant to the provisions of paragraphs (C) and (D) of Article
(below) of these Instructions, provided that such document shall be signed by the customer or his representative. The latter shall
submit a proof of his legal status as the representative.
b) The company is not obliged to obtain information regarding the purpose and nature of the required business relationship between
the customer and the company.
c) The company is not obliged to verify the identification of the Beneficial Owner.
http://www.amlu.gov.jo/AMLU_Images/634317170133933184.pdf
For purposes of applying the provisions of paragraph (A) of the Article in the link below, simplified procedures for identifying the customer
and his activity shall include the following:-
a) The customer shall submit a document with the required data pursuant to the provisions of paragraphs (C) and (D) of Article
(below) of these Instructions, provided that such document shall be signed by the customer or his representative. The latter shall
submit a proof of his legal status as the representative.
b) The company is not obliged to obtain information regarding the purpose and nature of the required business relationship between

the customer and the company.
c) The company is not obliged to verify the identification of the Beneficial Owner.
A13. Banks:
The bank shall undertake enhanced due diligence procedures in the following cases:
a) Opening an account by correspondence, a recommendation or proper authentication of the signature shall be obtained from
reputable banks or financial institutions.
b) Requesting facilities against deposits.
c) Leasing safe deposit boxes.
d) Depositing cash amounts or travellers cheques in an existing account by a person(s) that do not represent the owner of the
account under a power of attorney or authorization approved by the bank.
Insurance:
The company shall apply enhanced procedures for identifying the customer and his activity in the following cases:
a) Large insurance transactions and those which have no apparent economic or visible lawful purpose; the company shall put the
necessary procedures to examine the background and surrounding circumstances of such transactions and their purposes, and
shall keep the results of such examination in its records.
b) Insurance transactions with persons residing in or coming from countries which do not have appropriate anti money laundering
and counter terrorist financing systems or which do not apply or insufficiently apply the international standards related to anti
money laundering and counter terrorist financing, including the FATF recommendations.
c) Any transaction that the company believes by its own estimation forms a high level of money laundering and terrorist financing
risks.
d) Dealing with politically exposed persons.
A14. Banks:
Customers that are considered high risk customers: politically exposed persons, non-resident customers, private banking customers and
customers who belong to or are in countries that do not apply or insufficiently apply the FATF Recommendations.
The bank shall take the following procedures on the customer categories mentioned above:
a) The bank shall set appropriate risk management system to determine whether a potential customer, a customer or the beneficial
owner is one of said categories.
b) The approval of the banks general manager, regional manager, or the person authorised thereby shall be obtained when
commencing a relationship with these customers. Such approval shall also be obtained when a customer or a beneficiary owner is
discovered to be under such categories.
c) The bank shall take all necessary procedures to verify the sources of the wealth of customers and beneficiary owners who fall
under such categories.
d) The bank shall accurately and continuously monitor the transactions with such customers and give special attention to business
relationships and transactions that occur with any of them.
e) The bank shall exert the necessary procedures to identify the surrounding circumstances of such business relationships and
transactions and purposes thereof, if the bank becomes aware that any of them have no clear economic substances, and then
maintain records of the outcome.
Insurance:
For purposes of applying the provisions of paragraph (A) of the article below, the company shall comply with the following when dealing with
politically exposed persons:-
a) Put in place an appropriate risk management system to determine whether the customer or his representative or the Beneficial
Owner is a politically exposed person. The board of directors of the company shall establish a customer acceptance policy with
regard to politically exposed persons, taking into account classifying customers according to their risk.
b) The approval of the company general manager, authorised manger, or the person authorised thereby shall be obtained when
commencing a relation with these customers. Such approval shall also be obtained when a customer or a beneficiary owner is
c) Take sufficient procedures to identify the source of wealth of customers and Beneficial Owners who fall under such categories.
d) Conduct enhanced ongoing monitoring on the company's dealings with politically exposed persons.
A15. Dealing with external Banks

a) The bank shall apply the customer due diligence requirements in relation to customers stated in article (3) (linked below) when
commencing a relation with an external bank.
b) The bank shall verify the nature of the external banks business activity and reputation thereof in the field of anti money laundering
and counter terrorist financing transactions.
c) The approval of the banks general manager or regional manager shall be obtained before the commencement of a relation with
an external bank.
d) The bank shall ensure that the external bank is subject to an effective supervision by a supervisory authority in the banks home
country.
e) Anti-money laundering and counter terrorist financing systems shall be verified by the bank and applied by the external bank.
f) The bank shall ensure that the external bank has exerted due diligence regarding its customers who have authority to use
(payable-through accounts) and that the external bank is able to provide information related to such customers and transactions
made to such accounts when needed.
Owner is a politically exposed person. The board of directors of the company shall establish a customer acceptance policy with
regard to politically exposed persons, taking into account classifying customers according to their risk.
b) The approval of the company general manager, authorised manger, or the person authorised thereby shall be obtained when
commencing a relation with these customers. Such approval shall also be obtained when a customer or a beneficiary owner is
Questionsc) and Answers:
Take sufficient procedures to identify the source of wealth of customers and Beneficial Owners who fall under such categories.

d) Conduct enhanced ongoing monitoring on the company's dealings with politically exposed persons.
A15. Dealing with external Banks

a) The bank shall apply the customer due diligence requirements in relation to customers stated in article (3) (linked below) when
commencing a relation with an external bank.
b) The bank shall verify the nature of the external banks business activity and reputation thereof in the field of anti money laundering
and counter terrorist financing transactions.
c) The approval of the banks general manager or regional manager shall be obtained before the commencement of a relation with
an external bank.
d) The bank shall ensure that the external bank is subject to an effective supervision by a supervisory authority in the banks home
country.
e) Anti-money laundering and counter terrorist financing systems shall be verified by the bank and applied by the external bank.
f) The bank shall ensure that the external bank has exerted due diligence regarding its customers who have authority to use
(payable-through accounts) and that the external bank is able to provide information related to such customers and transactions
made to such accounts when needed.
A16. The bank shall not be permitted to keep numbered accounts or enter into banking relations with anonymous persons, persons with false or
fictitious names or shell companies or banks.
A17. The bank shall put the necessary policies and procedures to avoid risks related to misuse of indirect (Non Face to Face) dealing with
customers and applied effectively, especially those performed by virtue of advanced technology methods such as, ATM and banking
services through phone and internet banking taking into consideration the instructions of the Central Bank in this regard.
Reporting
A18. First: If any administrator in the bank suspects that the transaction to be executed is suspected to be related to money laundering or terrorist
financing, he/she shall notify the Reporting Officer.
Second: The Reporting Officer shall notify the Unit immediately of transactions suspected to be related to money laundering or terrorist
financing whether such transactions have taken place or are not pursuant to the form or means approved by the Unit and not to close the
account/accounts of the suspects.
Third: The Reporting Officer shall be responsible for providing the Unit and the competent authorities with the data that relate to transactions
suspected to be related to money laundering or terrorist financing and any other information requested, and facilitate its review of any
relevant records or documents for the performance of its duties.
Fourth:
a) Disclosure by any administrator, whether directly, indirectly or by any means, of notifying the Unit or any notification procedures
taken against transactions suspected to be related to money laundering or terrorist financing or data related thereto shall be
prohibited.
b) Disclosure by persons who have access to or that comes to their knowledge ex-officio, directly or indirectly, of any information
provided or exchanged in accordance with the provisions of law, regulations and instructions issued pursuant thereto, including
these instructions, shall be prohibited .
Fifth: The bank shall prepare files for transactions suspected to be related to money laundering or terrorist financing in which copies of
notifications for said transactions, documents and data related thereto shall be kept. Said files shall be kept at least for five years or until a
final adjudication is issued with regard to the transaction, whichever is longer.
A20. Specifying the duties of the Reporting Officer to include at the minimum:
a) Receiving information and reports on unusual and transactions suspected to be related to money laundering or terrorist financing,
examining the same and taking the appropriate decision with respect to notifying the Unit thereof or maintaining the same,
provided that the decision of maintaining such is justifiable.
b) Maintaining all documents and reports received.
c) Preparing periodic reports to the board of directors about all unusual and transactions suspected to be related to money
notifications for said transactions, documents and data related thereto shall be kept. Said files shall be kept at least for five years or until a
final adjudication is issued with regard to the transaction, whichever is longer.

Know
Information on the volume of SARs is not publicly available.

Country
A20. Specifying the duties of the Reporting Officer to include at the minimum:
a) Receiving information and reports on unusual and transactions suspected to be related to money laundering or terrorist financing,
examining the same and taking the appropriate decision with respect to notifying the Unit thereof or maintaining the same,
provided that the decision of maintaining such is justifiable.
b) Maintaining all documents and reports received.
c) Preparing periodic reports to the board of directors about all unusual and transactions suspected to be related to money
A21. No.
A22. Yes. Non compliance shall be reported in the external auditors report.
A23. No.
A24. Yes. They should be reported to the Anti Money Laundering and Counter Terrorist Financing in Jordan and the unit will recommend to
proceed or not.
A25. Not clearly stated in the regulations.
www.pwc.com.
Israel
Key contact: Eyal Ben-Avi Postal address: Last updated:
Email: eyal.ben-avi@il.pwc.com 25 Hamered Street, Tel Aviv 68125 Israel January 2013
Tel: +972 54 666 0203
General
A1. 2002.
A2. N/A.
A3. a) Banking Bank of Israel - http://www.bankisrael.gov.il/

b) Other financial services:
a. Israel securities authority - http://www.isa.gov.il/
b. Ministry of finance - http://ozar.mof.gov.il
c) None.
A4. Yes, IMPA (the Israeli Financial Intelligence Unit (FIU)) - http://www.justice.gov.il/MOJEng/Halbanat+Hon
A5. Yes.
A6. Yes.
A7. Yes, Israel was reviewed in August 2008 by Moneyval. This report is available at :
http://www.coe.int/t/dghl/monitoring/moneyval/Countries/Israel_en.asp
A8. No.
.
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A9. Individuals: should obtain name, address, identification number, date of birth and gender. Passports and identity cards are suitable for
verification purposes.
Corporates: should obtain name, address, identification number, date of incorporation. For controlling shareholders the same information
as for individuals should be obtained. Memorandum and Articles of Association and Certificates of Incorporation are suitable for verification
purposes.
A10. Document copies should be certified by an appropriate person, for example a notary, lawyer or accountant. In addition, verification in
accordance with the Population Registry should be performed.
A11. Banks should require the applicants to declare whether they are acting for themselves or on behalf of another. If an applicant declares that
he/she is acting on behalf of another, the declaration should include the particulars as set out in the guidance notes in respect of each of the
beneficiaries.
A12. Reduced/simplified due diligence arrangements apply for financial institutions which provide financial services, want to open a new account
for their beneficial use only and when the institution has an account in the banking corporation.
A13. The law provides information about customers and distinguishes between Israeli citizens and non Israeli citizens. For non citizens there are
legal demands for ensuring all the activities are globally accepted. When opening a correspondent account for a corporation incorporated in
a country that is not a member of the OECD, the banking corporation shall also obtain documents detailing the local guidance, and shall
retain them for at least seven years after the account is closed. The decision for undertaking enhanced due diligence should be taken and
documented in accordance with the risk based approach.
A14. Foreign PEPs are automatically considered high risk clients and are subject to additional procedures.
A15. The banking corporation should obtain the following:

a) name;
b) name of the country and supervisory authority;
c) general information (this is the address and telephone number of the corporation and names of persons to contact, according to
the Banking Order);
d) name and address of all shareholders above 20%; and
e) last annual report and reaust letter (letter requesting the opening of an account to be retained for at least 7 years after the
account closed).
When the correspondent is not from the OECD, the bank should obtain a licence from the supervisory authority, the incorporation
documents and letters of reference from banks in OECD member countries that manage accounts of the corporation wishing to open an
account. In addition Israeli banks should examine the efforts taken by the correspondent bank to defend against money laundering and
terrorist financing.
A16. Yes however, where a correspondent bank is related to a supervised banking corporation, engagements are allowed.
.
A17. Where a customer approaches a firm by post, telephone or over the internet, it should carry out non face-to-face verification, either
electronically or by reference to documents.
Reporting
A18. IMPA - the Israeli Financial Intelligence Unit (FIU) - http://www.justice.gov.il/MOJEng/Halbanat+Hon
A19. Information of the volume of SARs reported is not publicly available.
A20. Yes, financial institutions are obliged to report cases such as unusual transactions, cash transactions above ILS50,000, international wire
transfers to high risk countries, withdrawal of money which is not in line with usual pattern of business etc.
There is a list published by the regulators which provides examples of what suspicious behaviour might look like.
A21. At most financial institutions transactions under ILS50,000 do not need to be reported.
A22. Yes, the regulators can fine the controlled institutions. The maximum fine that controlled/supervised institutions can face is ILS2,260,000 for
each violation.
A23. No, although several institutions use automated suspicious transaction monitoring technology.
A24. The regulators only require that monitored institutions report the transaction to the FIU there is no requirement to wait for the authority to
proceed.
A25. No.
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Iraq
Key contact: Radwan Qutteneh Postal address: Golan Street - English Village Last updated: January
Email: radwan.qutteneh@iq.pwc.com Villa 252, Erbil, Iraq 2013
Tel: +964 780 921 5273
General
A1. Iraqi AML law became effective in 2004.
A2. N/A.
A3. a) Central Bank of Iraq http://www.cbi.iq

b) N/A
c) N/A
A4. N/A.
A5. N/A.
A6. The Law is silent in this regard; however, thresholds are determined for transactions that must be in compliance.
Q7. Has the country been the subject of a FATF (or FATF-style) Mutual Evaluation or IMF assessment exercise since 2003? If yes, please find a
A7. Information on whether the country has been subject to any FATF (Financial Action Task Force) assessment is not publicly available.
A8. Financial Institution shall question account holders for cash transaction greater than IQD10m. In addition, transactions below IQD5m for non
account holders require the collection and verification of customer name and address.
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A9. a) Legal name and any other names used

b) Detailed permanent address
c) Telephone number
d) Charter of establishing documents
e) Nationality identification
f) Official identification number
A10. The law did not specify anything other than the mentioned requirements above.
A11. In addition to the mentioned requirements, customers are required to provide a written declaration of the owner of the funds.
A12. None.
A13. The Law is silent in this regard.
A15. Cross border transactions above IQD15m require the submission of a report to the Money Laundering Reporting Office and/or Iraq Customs
Services. The report shall contain:
a) The legal capacity of the person filing the report;
b) The origin, destination and route of the currency;
c) The amount and type of monetary instruments; and
d) Any other additional information.
Reporting
.

In what circumstances is additional due diligence required for non face-to-face transactions and/or relationships?
Q17.
Know
A17.
The Law is silent in this regard.
Reporting
.
A18. Money Laundering Reporting Office at CBI: www.cbi.iq .
A20. Yes, Banks are encouraged to report suspicious transactions to the MLRO at CBI.
A21. The Law does not specify de-minimis thresholds; however thresholds were determined to report any amount exceeding those thresholds, as
discussed in the answer to question number 8.
A22. The CBI may impose the following if a financial institution violated the law:
a) Issue an order to cease the activity resulting in the violation;
b) Assess a monetary penalty;
c) Publish the results of any enforcement action; or
d) Issue an order to prohibit t the violating party from being involved in the affairs of financial institution either permanently or
temporary.
A23. No.
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.
Bahrain
Key contact: Madhukar Shenoy Postal address: Last updated:
th
Email: madhukar.shenoy@bh.pwc.com TJ Tower, 13 Floor, Seef District; January 2013
Tel: +973 1 711 8800 Manama; Bahrain
General
A1. 2001 (amended 2006). The Anti Money Laundering & Terrorist Financing Unit (AMLTFU) was established in July 2002, under the direct
control of the Ministry of the Interior. The AMLTFU is the money laundering enforcement unit in the Kingdom of Bahrain responsible for
receiving, requesting, analysing and disseminating disclosures of financial information to the investigatory and supervisory authorities
concerning suspected proceeds of crime and alleged money laundering.
A2. N/A
A3. Central Bank of Bahrain (CBB) is responsible for enforcing AML controls for CBB licensed institutions including banks and other institutions
in the financial services sector. The Ministry of Industry and Commerce is responsible for enforcing AML controls for the non financial
sector. http://www.cbb.gov.bh
A4. Yes.
CBB website for information on AML & Combating the Financing of Terrorism (CFT):
http://www.cbb.gov.bh/page.php?p=aml_cft
The Ministerial Order No.23 of 2002
A5. No.
A6. Yes, the Central Bank of Bahrain (CBB) uses a risk based approach to customer due diligence and ongoing monitoring through its
rulebooks. The CBB requires banks to have effective anti-money laundering policies and procedures in addition to measures for combating
the financing of terrorism.
A7. No, Bahrain's compliance with international AML/CFT standards was assessed by the International Monetary Fund in 2005, as part of a
financial sector assessment programme review of the Kingdom. The report was approved by the IMF in January 2006. The same report was
subsequently discussed and endorsed by the MENA-FATF in November 2006.
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rulebooks. The CBB requires banks to have effective anti-money laundering policies and procedures in addition to measures for combating
the financing of terrorism.
Q7. please find

Questions
anda linkAnswers:
Know
No, Bahrain's compliance with international AML/CFT standards was assessed by the International Monetary Fund in 2005, as part of a
financial sector assessment programme review of the Kingdom. The report was approved by the IMF in January 2006. The same report was
Country by country discussed
subsequently comparison of high by
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MENA-FATF and Anti-Money Laundering information
November 2006.
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thresholds interest for the personal use of the reader, and does not constitute professional advice. You should not act upon the information
A8. Yes. or assume any liability, responsibility or duty of care for any consequences of you or anyone else acting, or refraining to act, in reliance on the information contained in this
agents do not accept
Financial institutions:
The Financial Crime module of CBB Rulebook Volume 1

(http://cbb.complinet.com/cbb/display/display.html?rbid=1820&element_id=5272)states that a bank must implement customer due diligence
measures when:
a) Establishing business relations with a new or existing customer;
b) A change to the signatory or beneficiary of an existing account or business relationship is made;
c) A significant transaction takes place;
d) There is a material change in the way that the bank account is operated or in the manner in which the business relationship is
conducted;
e) Customer documentation standards change substantially;
f) The bank has doubts about the veracity or adequacy of previously obtained customer due diligence information;
g) Carrying-out one-off or occasional transactions above BHD6,000, or where several smaller transactions that appear to be linked
fall above this threshold;
h) Carrying out wire transfers irrespective of amount; or
i) There is a suspicion of money laundering or terrorist financing.
Non financial institutions:

Article 4 of Ministerial Order No.23 of 2002 () exempts the following transactions from customer due diligence:
a) the transaction or transactions which total less than BHD10,000;
b) transactions related to life insurance if the premiums are paid through an account opened for the customer in a local bank; and
c) transactions related to a retirement scheme if they arise from the Insured's occupation or contract of employment or if the amount
of subscriptions is paid through an account opened for the customer in a local bank.
A9. Financial institutions:

The Financial Crime module (FC 1.2) of CBB Rulebook Volume 1
( http://cbb.complinet.com/cbb/display/display.html?rbid=1820&element_id=5272) states that banks must obtain and record the following
information, where applicable:
In the case of natural person:
Full legal name and any other names used / Full permanent address / Date and place of birth / Nationality / Passport number /
CPR or residency number / Telephone/fax number / email address / Occupation or public position held / Employer's name and
address (if self-employed, the nature of the self-employment) / Type of account and nature and volume of anticipated business
dealings with the conventional bank licensee/Signature of the customer(s) / Source of funds.
In the case of legal entities:
The entity's full name and other trading names used / Registration number (or equivalent) / Legal form / Registered address and
trading address / Type of business activity / Date and place of incorporation or establishment / Telephone, fax number and email
address / Regulatory body or listing body (for regulated activities such as financial services and listed companies) / Name of
external auditor / Type of account, and nature and volume of anticipated business dealings with conventional bank licensees/ /
Source of funds.
The information obtained must be verified in accordance with CBB requirements as per FC 1.2.4 to FC 1.2.6 and FC 1.2.8.
Article 4 of Ministerial Order No.23 of 2002 () identifies details to be established and kept on record for non financial institutions where
applicable:
In the case of natural persons:
Customers full name / Date of birth / Nationality / Full details of the identity card or passport / Central Population Register (CPR)
Card number (if any) / Occupation / Usual residence address / Employers name and address.
In the case of a corporate client:
Customers full name / Legal status / Registration number and place / Address of the head office and branches (if any) / Names of
board members / Legal representative of the corporate person and his identification. The Memorandum and Articles of
Association and the Power of Attorney must also be verified for incorporated activities.
.

The Financial Crime module (FC 1.2.4 and FC - 1.2.5) of CBB Rulebook Volume 1
(http://cbb.complinet.com/cbb/display/display.html?rbid=1820&element_id=5272) states that an authorised official of the licensee must
certify copy documents, by viewing the original and writing on the copy the words original sighted, together with the date and a signature.
Equivalent measures must be taken for electronic copies. Identification documents which are not obtained by an authorised official of the
licensee in original form must instead be certified by one of the following from a Gulf Cooperation Council (GCC) or FATF member state: a
lawyer; a notary; a chartered/certified accountant; an official of a government ministry; an official of an embassy or consulate; or an official of
another licensed financial institution or of an associate company of the licensee.

Article 4 of Ministerial Order No.23 of 2002 () details that before establishing any business relationship, registered persons shall establish
the identities of their customers, representatives and beneficiaries from the transaction by using all the reasonable methods and adopt all
the possible precautions to ascertain the validity of documents or details concerning their identities.

The Financial Crime module (FC 1.1.5 to FC - 1.1.7 and FC - 1.6.1) of CBB Rulebook Volume 1
(http://cbb.complinet.com/cbb/display/display.html?rbid=1820&element_id=5272) states that banks must obtain a signed statement from all
new customers confirming whether or not the customer is acting on their own behalf. This undertaking must be obtained prior to conducting
any transactions with the customer concerned.
Where a customer is acting on behalf of a third party, the bank must also obtain a signed statement from the third party, confirming they
have given authority to the customer to act on their behalf. Where the third party is a legal person, the bank must have sight of the original
board resolution (or other applicable document) authorising the customer to act on the third partys behalf, and retain a certified copy.
Banks must establish and verify the identity of the customer and (where applicable) the party/parties on whose behalf the customer is acting,
including the beneficial owner of the funds.
Financial services must not be provided to charitable funds and religious, sporting, social, cooperative and professional societies, until an
original certificate authenticated by the relevant Ministry confirming the identities of those purporting to act on their behalf (and authorising
them to obtain the said service) has been obtained.

Ministerial Order No.7 of 2001 (requires each institution to verify a customers identity and his source of funds and obtain proof that:
a) Establishes the customer's identity;
b) Establishes that the source of funds is as claimed by the customer;
c) Determines the customer's address, date of birth and nationality. If the customer is an agent of a business or firm subject to the
supervision of a controlling authority and resides in a country that has similar laws for prohibition and combating money
laundering, it may be sufficient evidence to receive written confirmation from the customer of the availability of proof of the
principals identity, its registration and maintenance thereof.
.

The Financial Crime module (FC 1.11) of CBB Rulebook Volume 1
(http://cbb.complinet.com/cbb/display/display.html?rbid=1820&element_id=5272) states that banks may apply simplified due diligence if the
customer is:
a) The customer is the CBB, the Bahrain Stock Exchange (BSE) or a licensee of the CBB;
b) The customer is a Ministry of a Gulf Cooperation Council (GCC) or Financial Action Task Force (FATF) member state
government, a company in which a GCC or FATF government is a majority shareholder, or a company established by decree in
the GCC;
c) The customer is a company listed on a GCC or FATF member state stock exchange (where the FATF state stock exchange has
equivalent disclosure standards to those of the BSE);
d) The customer is a financial institution whose entire operations are subject to AML/CFT requirements consistent with the FATF
recommendations / special recommendations and it is supervised by a financial services supervisor in a FATF or GCC member
state for compliance with those requirements;
e) The customer is a financial institution which is a subsidiary of a financial institution located in a FATF or GCC member state, and
the AML/CFT requirements applied to its parent also apply to the subsidiary;
f) The customer is a borrower in a syndicated transaction where the agent bank is a financial institution whose entire operations are
subject to AML/CFT requirements consistent with the FATF recommendations / special recommendations and it is supervised by
a financial services supervisor in a FATF or GCC member state for compliance with those requirements;
g) The transaction is a one-off or occasional transaction not exceeding BHD6,000 (or equivalent in other currencies), or one of a
number of transactions which are related and, when taken together, do not exceed BHD6,000 per year (or equivalent in other
currencies).

Article 4.7 of Ministerial Order No.7 of 2001 (specifies that procedures for proving a customer's identity and sources of funds of the following
shall not be applicable if:
a) The customer is an organisation affiliated to or under the supervision of the Ministry of Commerce and Industry, the Bahrain Stock
Exchange, the Ministry of Justice or if it is a company in which the government has a majority stake, or if it is a company
incorporated by virtue of a law or decree;
b) The subject matter of the transaction is the payment of sums by the customer or on his behalf through another organisation;
c) A separate significant transaction takes place with or for the account of a third party with the intervention of a person who is
subject to a supervisory authority, who has provided confirmation that the identity of the third party has been established and
registered according to the custody procedures of such person;
d) The customer purchases a stake in a collective investment venture.
A13. The CBB Rulebook Volume 1, Financial Crime module FC 1.3 to FC 1.8
(http://cbb.complinet.com/cbb/display/display.html?rbid=1820&element_id=5272) states that enhanced customer due diligence must be
performed on those customers identified as having a higher risk profile and additional enquiries made or information obtained in respect of
those customers. Specific conditions that give rise to a higher risk profile include:
Instances where there is non-face-to-face business; dealing with Politically Exposed Persons (PEPs); dealing with charities, clubs and
other societies; dealing with a professional intermediary who manages pooled funds; and dealing with a correspondent bank.
A14. The Financial Crime module (FC 1.5) of CBB Rulebook Volume 1
(http://cbb.complinet.com/cbb/display/display.html?rbid=1820&element_id=5272) states that Banks must have appropriate risk
management systems to determine whether a customer is a PEP, both at the time of establishing business relations and thereafter on a
periodic basis. Banks must utilise publicly available databases and information to establish whether a customer is a PEP.
Banks must establish a client acceptance policy with regard to PEPs, taking into account the reputational and other risks involved. Senior
management approval must be obtained before a PEP is accepted as a customer. Where an existing customer is a PEP, or subsequently
becomes a PEP, enhanced monitoring and customer due diligence measures must include:
a) analysis of complex financial structures, including trusts, foundations or international business corporations;
b) a written record in the customer file to evidence that reasonable measures have been taken to establish both the source of wealth
and the source of funds;
c) development of a profile of anticipated customer activity, to be used in ongoing monitoring;
d) approval of senior management for allowing the customer relationship to continue; and
e) on-going account monitoring of the PEPs account by senior management (such as the Money Laundering Reporting Officer
(MLRO).
.
(http://cbb.complinet.com/cbb/display/display.html?rbid=1820&element_id=5272) states that Banks must implement the following additional
measures, prior to opening a correspondent banking relationship:
a) Complete a signed statement that outlines the respective responsibilities of each institution in relation to money laundering
detection and monitoring responsibilities; and
b) Ensure that the correspondent banking relationship has the approval of senior management.
Banks which intend to act as correspondent banks must gather sufficient additional information (e.g. through a questionnaire) about their
respondent banks to understand the nature of the respondent's business. Factors to consider include:
a) Information about the respondent bank's ownership, structure and management;
b) Major business activities of the respondent and its location (i.e. whether it is located in a FATF compliant jurisdiction) as well as
the location of its parent (where applicable);
c) Where the customers of the respondent bank are located;
d) The respondent's AML and Combating the Financing of Terrorism (CFT) controls;
e) The purpose for which the account will be opened;
f) Confirmation that the respondent bank has verified the identity of any third party entities that will have direct access to the
correspondent banking services without reference to the respondent bank;
g) The extent to which the respondent bank performs on-going due diligence on customers with direct access to the account, and
the condition of bank regulation and supervision in the respondent's country (e.g. from published FATF reports). Banks should
take into account the country where the respondent bank is located and whether that country abides by the FATF 40+ 9
recommendations when establishing correspondent relationships with foreign banks. Banks should obtain where possible copies
of the relevant laws and regulations concerning AML/CFT and satisfy themselves that respondent banks have effective customer
due diligence measures consistent with the FATF 40+ 9 recommendations;
h) Confirmation that the respondent bank is able to provide relevant customer identification data on request to the correspondent
bank; and
i) Whether the respondent bank has been subject to a money laundering or terrorist financing investigation.
A16. Yes. The Financial Crime module (FC 1.10) of CBB Rulebook Volume 1
(http://cbb.complinet.com/cbb/display/display.html?rbid=1820&element_id=5272) states that Banks must not establish business relations
with banks which have no physical presence or 'mind and management' in the jurisdiction in which they are licensed and which is
unaffiliated with a regulated financial group. Banks must not knowingly establish relations with banks that have relations with shell banks.
(http://cbb.complinet.com/cbb/display/display.html?rbid=1820&element_id=5272) states that where no face-to-face contact takes place,
banks must take additional measures in order to mitigate the potentially higher risk associated with such business. In particular, banks must
take measures to ensure that the customer is the person they claim to be and that the address provided is genuinely the customer's. There
are a number of checks that can provide a bank with a reasonable degree of assurance as to the authenticity of the applicant:
a) Telephone contact with the applicant on an independently verified home or business number;
b) With the customer's consent, contacting an employer to confirm employment, via phone through a listed number or in writing; and
c) Salary details appearing on recent bank statements.
Reporting
A18. For licensees registered under the CBB, SARs must be simultaneously sent to both the CBB (www.cbb.gov.bh) and the Anti Money
Laundering & Terrorist Financing Unit (AMLTFU) ().
For licensees registered under the Ministry of Industry and Commerce, SARs must be simultaneously sent to both the MOIC
(http://www.moic.gov.bh/Moic/En/Legal) and the AMLTFU.
.
A19. Information of the volume of SARs is not publicly available.
A20. Financial Institutions:

The Financial Crime module (FC 5.1.1) of CBB Rulebook Volume 1
(http://cbb.complinet.com/cbb/display/display.html?rbid=1820&element_id=5272) specifies that banks must implement procedures to ensure
that staff who handle customer business (or are managerially responsible for such staff) make a report promptly to the MLRO if they know or
suspect that a customer (or a person on whose behalf a customer may be acting) is engaged in money laundering or terrorism financing, or
if the transaction or the customer's conduct otherwise appears unusual or suspicious. These procedures must include arrangements for
disciplining any member of staff who fails, without reasonable excuse, to make such a report.
Ministerial Order No.7 of 2001 Article 4.9) specifies that all institutions shall report to the Anti Money Laundering Unit any suspicious or
extraordinary transactions regardless of the value of amounts subject to the transaction.
A21. A transaction needs to be reported if it is above BHD6,000 or where several smaller transactions that appear to be linked fall above this
threshold. If the transactions fall below this threshold, they do not need to be reported.
A22. Article 3.4 and Article 3.5 of Law No. (4) of 2001 (http://cbb.complinet.com/file_store/pdf/rulebooks/AppendixFC1.pdf) specifies that:
a) Any person who commits any of the offences related to money laundering shall be liable to imprisonment for a period not
exceeding two (2) years and/or a fine not exceeding BHD50,000 or both.
b) Any person who contravenes the provisions of Regulations and Ministerial Regulations issued under this law shall be liable to
imprisonment for a period not exceeding three (3) months or a fine not exceeding BHD 20,000 or both.
A23. The Financial Crime module (FC 2.1 and FC 2.2) of CBB Rulebook Volume 1
(http://cbb.complinet.com/cbb/display/display.html?rbid=1820&element_id=5272) specifies that banks must take reasonable care to
establish and maintain appropriate systems and controls to limit their vulnerability to financial crime. These systems and controls must be
documented, and approved and reviewed annually by the Board of the bank. The documentation and the Board's review and approval, must
be made available upon request to the CBB.
Banks must develop risk-based monitoring systems appropriate to the complexity of their business, their number of clients and types of
transactions. These systems must be configured to identify significant or abnormal transactions or patterns of activity. Such systems must
include limits on the number, types or size of transactions undertaken outside expected norms; and must include limits for cash and non-
cash transactions.
The banks risk-based monitoring systems should therefore be configured to help identify:
a) Transactions which do not appear to have a clear purpose or which make no obvious economic sense;
b) Significant or large transactions not consistent with the normal or expected behaviour of a customer; and
c) Unusual patterns of activity (relative to other customers of the same profile or of similar types of transactions, for instance
because of differences in terms of volumes, transaction type, or flows to or from certain countries), or activity outside the expected
or regular pattern of a customer's account activity.
Banks must consider the need to include automated transaction monitoring as part of their risk-based monitoring systems to spot abnormal
or unusual flows of funds. In the absence of automated transaction monitoring systems, all transactions above BHD6,000 must be viewed as
significant and be captured in a daily transactions report for monitoring by the MLRO or a relevant delegated official, and records to be
retained by the bank for five years after the date of the transaction.
.
A24. No, unless the bank is specifically requested by the CBB to do so.
A25. Article 8 of Law No. (4) of 2001 (http://cbb.complinet.com/file_store/pdf/rulebooks/AppendixFC1.pdf) states that where a foreign state makes
a request for specific information relating to suspicious transactions, persons and corporations involved in those transactions or the
investigation or prosecution of a money laundering offence, the AMLTFU shall execute the request or inform the foreign state of any delay in
or the reason for not executing the request.
.
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Know Your Customer:

Know Your Customer: Quick Reference Guide

Know Your Customer: Quick Reference Guide

Know Your Customer: Quick Reference Guide

Know Your Customer: Quick Reference Guide

Know Your Customer: Quick Reference Guide

Know Your Customer: Quick Reference Guide

A3. Bank of Zambia - http://www.boz.zm/

Q6. Is a risk based approach approved by the local regulator(s)?

Customer due diligence

The Financial Intelligence Centre Act stipulates that:

A10. Certification of relevant identification copies by a Commissioner of Oaths.

Q12. In what circumstances are reduced/simplified due diligence arrangements available?

Q16. Are relationships with shell banks specifically prohibited?

A19. Information on the volume of SARs is not publicly available.

PricewaterhouseCoopers International Limited, in thisofpublication

A1. AML laws

Q6. Is a risk based approach approved by the local regulator(s)?

Q12. In what circumstances are reduced/simplified due diligence arrangements available?

Q16. Are relationships with shell banks specifically prohibited?

A19. Volume of SARs:

GDP (in current prices):

This results in a ratio of 1 SAR for every USD7.6 million of GDP.

A21. byTransactions below ZAR24,999 need not be reported.

Q6. Is a risk based approach approved by the local regulator(s)?

Customer due diligence

Know Your Customer quick reference guide

Customer due diligence

Q12. In what circumstances are reduced/simplified due diligence arrangements available?

A12. None stated in local regulations or guidance.

A13. None stated in local regulations or guidance.

A14. None stated in local regulations or guidance.

A19. Information on the volume of SARs is not publicly available.

A3. Financial Intelligence Centre (website not available).

A4. Yes (website not available).

Q6. Is a risk based approach approved by the local regulator(s)?

Customer due diligence

A8. Yes equivalent of USD10,000.

Q12. In what circumstances are reduced/simplified due diligence arrangements available?

Q16. Are relationships with shell banks specifically prohibited?

A18. Financial Intelligence Centre (website not available).

A19. Information on the volume of SARs is not publicly available.

PricewaterhouseCoopers International Limited, in

A3. a) Banking Commission. www.beac.int

A5. Yes - an update of the customer database is required.

Q6. Is a risk based approach approved by the local regulator(s)?

A6. No There is no risk based approach approved by the local regulator.

Customer due diligence

A9. The requirements are:

A11. The requirements are:

Q12. In what circumstances are reduced/simplified due diligence arrangements available?

A13. Customer due diligence is enhanced for unusual or suspicious activities/transactions.

Q16. Are relationships with shell banks specifically prohibited?

A19. Information on the volume of SARs is not publicly available.

Q6. Is a risk based approach approved by the local regulator(s)?

Customer due diligence

Q7. please find a link to a relevant report (if publicly available).

Customer due diligence