Schedule B

GXI AML Questionnaire

ANTI-MONEY LAUNDERING / COUNTER TERRORISM FINANCING

QUESTIONNAIRE FOR NON FINANCIAL INSTITUTION
A. GENERAL INFORMATION

Full Legal Name of the Legal Entity (LE) SOFAREE DIGITAL MARKETING SERVICES
Other Business Name/s or Trade Names (if SOFAREE
applicable)

Full Legal (Registered) Address 355 PANTUA STREET TIMUGAN

LOS BANOS LAGUNA
Full Primary Business Address (if different from
above)

AUGUST 30, 2024

Date of Entity incorporation / establishment

Select type of ownership and append an ownership

chart if available
• Publicly Traded (25% of shares publicly traded)

- If Y, indicate the exchange traded on and

ticker symbol

• Member Owned / Mutual

• Government or State Owned by 25% or more

• Privately Owned

- If Y, provide details of shareholders or

ultimate beneficial owners with a holding of SOLE PROPRIETORSHIP
10% or more

Does the Entity, or any of its branches, operate NO

under an Offshore Banking License (OBL)?
 - If Y, provide the name of the relevant
branch/es which operate under an OBL

UNIONBANK, LANDBANK
List of Bank References

B. OWNERSHIP AND MANAGEMENT STRUCTURE

1. Is your institution a listed company?

x No
___ Yes __
If “Yes”, on which exchange its shares are traded?

2. Please provide, in a separate sheet of paper, the legal entity’s ownership structure, clearly identifying its ultimate
beneficial owner.
3. Please list the names of the shareholders, owners, or partners of your institution who, directly own, control or
has have voting power of at least twenty percent (20%) or more of any class of securities of your institution.

Name % Ownership

4. Please provide the information for authorized signatories:

Full Name Position Address Nationality

5. Please list the names and positions of the principal officers of your institution (Chairman, President, and Vice
President equivalent levels). Please use a separate sheet of paper if not sufficient.

Name Position Title / Rank

 6. Are there any politically-exposed persons (PEPs) among your institution’s shareholders, owners, directors, or
principal officers? ___ Yes ___x No

“Politically-Exposed Person” (PEP) refers to an individual who is or has been entrusted with prominent public
position in (a) the Philippines with substantial authority over policy, operations or the use or allocation of
government-owned resources; (b) a foreign State; or (c) an international organization.

If “Yes”, please provide the following information:

Name Position Title / Rank PEP Position / Designation

C. ANTI-MONEY LAUNDERING / COUNTER-TERRORISM FINANCING (AML/CTF) SANCTIONS PROGRAM

No Question Yes No Notes/Remarks

AML, CTF & Sanction Program

1.
Does the Entity have a program that sets minimum AML, CTF and x
Sanctions standards regarding the following components:
x
Appointed Officer with sufficient experience / expertise
x
Cash Reporting
x
Customer Due Diligence
x
Enhanced Due Diligence
x
Beneficial Ownership
x
Independent Testing
No Question Yes No Notes/Remarks
x
Periodic Review
x
Policies and Procedures
x
Risk Assessment
x
Sanctions
x
PEP Screening
x
Adverse Information Screening
x
Suspicious Activity Reporting
x
Training and Education
x
Transaction Monitoring
2.
Is the Entity's AML, CTF & Sanctions policy approved at least NA
annually by the Board or equivalent Senior Management
Committee?
3.
Does the Entity use third parties to carry out any components of x
its AML, CTF & Sanctions program?

If Y, provide further details

Anti-Bribery & Corruption

4 Has the Entity documented policies and procedures consistent x

with applicable ABC regulations and requirements to [reasonably]
prevent, detect and report bribery and corruption?

5 Does the Entity's internal audit function or other independent third x

party cover ABC Policies and Procedures?

6 Does the Entity provide mandatory ABC training to: NA

Board and Senior Committee Management

1st Line of Defense

2nd Line of Defense

3rd Line of Defense

3rd parties to which specific compliance activities subject to ABC

risk have been outsourced

Non-employed workers as appropriate (contractors / consultants)

Policies and Procedures

Has the Entity documented policies and procedures consistent
7 with applicable AML, CTF & Sanctions regulations and Y
requirements to reasonably prevent, detect and report:
Money laundering Y
Terrorist financing Y
No Question Yes No Notes/Remarks
Sanctions violations Y
Does the Entity have policies and procedures that:
8
Prohibit the opening and keeping of anonymous and fictitious
named accounts Y
Prohibit the opening and keeping of accounts for unlicensed NA
banks and / or NBFIs
Prohibit dealing with other entities that provide banking services Y
to unlicensed banks
Prohibit accounts / relationships with shell banks NA
Prohibit dealing with another Entity that provides services to shell Y
banks
Prohibit opening and keeping of accounts for any of unlicensed /
unregulated remittance agents, exchanges houses, casa de Y
cambio, bureaux de change or money transfer agents
Assess the risks of relationships with PEPs, including their family Y
and close associates
Define escalation processes for financial crime risk issues Y
Specify how potentially suspicious activity identified by employees Y
is to be escalated and investigated
Outline the processes regarding screening for sanctions, PEPs Y
and negative media
Has the Entity defined a risk tolerance statement or similar Y
9 document which defines a risk boundary around their business?
Does the Entity have a record retention procedures that comply Y
10 with applicable laws?
If Y, what is the retention period? 5 years

KYC, CDD and EDD

Does the Entity verify the identity of the customer? Y
11
Do the Entity's policies and procedures set out when CDD must N FMC SERVICE
12 be completed, e.g. at the time of onboarding or within 30 days
Which of the following does the Entity gather and retain when
13 conducting CDD? Select all that apply:
Ownership structure

Customer identification

Expected activity

Nature of business / employment

Product usage

Purpose and nature of relationship

Source of funds

Source of wealth

Are each of the following identified:

14
Ultimate beneficial ownership
No Question Yes No Notes/Remarks
Are ultimate beneficial owners verified?

Authorized signatories (where applicable)

Key controllers

Other relevant parties

Does the due diligence process result in customers receiving a N

15 risk classification?
Does the Entity have a risk based approach to screening
16 customers and connected parties to determine whether they are
PEPs, or controlled by PEPs?
Does the Entity have policies, procedures and processes to
17 review and escalate potential matches from screening customers
and connected parties to determine whether they are PEPs, or
controlled by PEPs?
Does the Entity have a process to review and update customer
18 information based on:
KYC renewal

Trigger event

From the list below, which categories of customers or industries

19 are subject to EDD and / or are restricted, or prohibited by the
Entity's FCC program?
Non-account customers
Y
Offshore customers
Y
Shell banks
Y
MVTS/ MSB customers
Y
PEPs
Y
PEP Related Y
PEP Close Associate
Y
Correspondent Banks Y
Arms, defense, military
Y
Atomic power
Y
Extractive industries
Y
Precious metals and stones
Y
Unregulated charities
Y
Regulated charities
Y
Red light business / Adult entertainment
Y
Non-Government Organization
Y
Virtual currencies
Y
No Question Yes No Notes/Remarks
Marijuana Y
Embassies / Consulates Y
Gambling Y
Payment Service Provider Y
Other (specify)

If restricted, provide details of the restriction

20

Monitoring and Reporting

Does the Entity have risk based policies, procedures and
21 monitoring processes for the identification and reporting of Y
suspicious activity?
What is the method used by the Entity to monitor transactions for
22 suspicious activities?
Automated

Manual

Combination of automated and manual Y

Does the Entity have regulatory requirements to report currency N
23 transactions?
If Y, does the Entity have policies, procedures and processes to
comply with currency reporting requirements?
Does the Entity have policies, procedures and processes to
24 review and escalate matters arising from the monitoring of
customer transactions and activity?

Sanctions
Does the Entity have policies, procedures or other controls
25 reasonably designed to prohibit and / or detect actions taken to
evade applicable sanctions prohibitions, such as stripping, or the
resubmission and / or masking, of sanctions relevant information
in cross border transactions?
Does the Entity screen its customers, including beneficial
26 ownership information collected by the Entity, during onboarding
and regularly thereafter against Sanctions Lists?
Select the Sanctions Lists used by the Entity in its sanctions
27 screening processes:
Consolidated United Nations Security Council Sanctions List (UN)

United States Department of the Treasury's Office of Foreign

Assets Control (OFAC)
Office of Financial Sanctions Implementation HMT (OFSI)

European Union Consolidated List (EU)

Other (specify)

Does the Entity have a physical presence, e.g., branches,

28 subsidiaries, or representative offices located in countries /
regions against which UN, OFAC, OFSI, EU and G7 member
countries have enacted comprehensive jurisdiction-based
Sanctions?
 No Question Yes No Notes/Remarks

Training and Education

Does the Entity provide mandatory training, which includes:
29
Identification and reporting of transactions to government
authorities
Examples of different forms of money laundering, terrorist
financing and sanctions violations relevant for the types of
products and services offered
Internal policies for controlling money laundering, terrorist
financing and sanctions violations
New issues that occur in the market, e.g., significant regulatory
actions or new regulations
Is the above mandatory training provided to:
30
Board and Senior Committee Management

1st Line of Defense

2nd Line of Defense

3rd Line of Defense

3rd parties to which specific FCC activities have been outsourced

Non-employed workers (contractors / consultants)

Audit
In addition to inspections by the government supervisors /
31 regulators, does the Entity have an internal audit function, a
testing function or other independent third party, or both, that
assesses FCC AML, CTF and Sanctions policies and practices on
a regular basis?

D. COMPLIANCE OFFICER OR PERSON DESIGNATED TO ADMINISTER AND IMPLEMENT THE AML/CTF

PROGRAM

Please provide information on the institution’s Chief Compliance Officer or the person designated to administer the
AML/CTF program of your institution:

PETER PANTILLA
Name
FOUNDER / OWNER
Position
335 PANTUA STREET TIMUGAN LOS BANOS
Mailing Address
peter@sofaree.com
E-mail Address
09499899460
Telephone No.
E. DOCUMENTS NEEDED FOR JURIDICAL ENTITIES [Account Manager (AM) will check if applicable to partners]


X SOLE PROPRIETORSHIP
• DTI Certificate of Registration
• One (1) valid government issued ID of the Proprietor/Owners
• Ultimate Beneficial Ownership (“UBO”)
 PARTNERSHIP
• SEC Certificate of Registration
• Articles of Partnership
• Partnership Resolution duly certified by the Partnership Secretary authorizing the signatory to
sign on behalf of the partnership (i.e. Secretary’s Certificate)
• One (1) valid government issued ID of the authorized representative
• UBO
 STOCK CORPORATION
• SEC Registration Certificate
• Board Resolution duly certified by the Corporate Secretary (i.e. Secretary’s Certificate)
authorizing the representative to sign on behalf of the corporation
• Articles of Incorporation
• Latest General Information Sheet
• One (1) valid government issued ID of the authorized representative
• UBO
 NON-STOCK CORPORATION (I.E. NGO/NPO/FOUNDATION)
• SEC Registration Certificate
• Board Resolution duly certified by the Corporate Secretary (i.e. Secretary’s Certificate)
authorizing the representative to sign on behalf of the corporation
• Articles of Incorporation
• Latest General Information Sheet (GIS)
• Either one of the following:
a. Income Tax Return
b. Latest Audited Financial Statements
c. Philippine Council for NGO Certification
d. SEC Mandatory Disclosure Form
• One (1) valid government issued ID of the authorized representative, President, Treasurer
 FOREIGN CORPORATIONS REGISTERED WITH SEC
• SEC Registration Certificate
• Board Resolution duly certified by the Corporate Secretary (i.e. Secretary’s Certificate)
authorizing the representative to sign on behalf of the corporation
• Articles of Incorporation
• Latest General Information Sheet
• One (1) valid government issued ID of the authorized representative
• UBO
 FOREIGN CORPORATIONS REGISTERED OUTSIDE THE PHILIPPINES
• SEC Registration Certificate
• Board Resolution duly certified by the Corporate Secretary (i.e. Secretary’s Certificate)
authorizing the representative to sign on behalf of the corporation
• Articles of Incorporation
• Latest General Information Sheet
• One (1) valid government issued ID of the authorized representative
• UBO
• Duly authenticated by the senior officer or the designated officer of the covered person assigned
in the country of registration, or in the absence of the officer, documents should be authenticated
by the Philippine Consulate, company register or notary public, where said entities are
registered.
 ONE PERSON CORPORATION
• SEC Registration Certificate
• Copy of the Commission/Certificate of Election/Letter of Appointment of the Chief
Archbishop/Bishop/Priest/Minister/Rabbi/Presiding Elder duly certified by a notary public
• Articles of Incorporation
• Written Consent Letter of the Nominee and Alternate Nominee
 • One (1) valid government issued ID of the authorized representative
• UBO
 CORPORATE SOLE
• SEC Registration Certificate
• Copy of the Commission/Certificate of Election/Letter of Appointment of the Chief
Archbishop/Bishop/Priest/Minister/Rabbi/Presiding Elder duly certified by a notary public
• Verified Articles of Incorporation
• One (1) valid government issued ID of the authorized representative
 RELIGIOUS SOCIETIES
• SEC Registration Certificate
• Latest General Information Sheet
• Verified Articles of Incorporation
• One (1) valid government issued ID of the authorized representative
 UNINCORPORATED ENTITIES
• Articles of Association or Constitution
• One (1) valid government issued ID of the authorized representative
• UBO
 COOPERATIVE
• Certificate of Registration issued by the Cooperative Development Authority (CDA)
• Articles of Cooperation
• Latest updated list of directors/trustees, officers, and individual members duly filed with CDA
• Board resolution duly certified by the Cooperative Secretary or authorized officer, authorizing
the signatory to sign on behalf of the cooperative
• One (1) valid government issued ID of the authorized representative
 UNION
• Certificate of Registration issued by the Regional Offices of the Bureau of Labor Relations, or
Charter Certificate issued by the National Federation or Union
• Constitution
• Latest updated list of officers and individual members duly filed with the Regional Office or
Bureau;
• UBO
• Officers’ resolution duly certified by the Union Secretary, or authorized officer, authorizing the
signatory to sign on behalf of the entity
• One (1) valid Identification Document of the authorized representative.
 EMBASSIES
• Letter from the Ambassador or Consulate Officer-in-Charge (using the Embassy's letterhead)
indicating the authority of the representative(s) to enter into business with SLFP; and
• One (1) valid Identification Document of the authorized representative and signed by the
Ambassador or Consulate Officer-in-Charge.
 GOVERNMENT/PUBLIC SECTOR
a. Local Government Unit (LGU)
• Barangay/Municipality/City Council/Provincial Board Resolution-authorizing the
engagement and disbursement of municipal, city or provincial funds
• DILG Certification for Seal of Good Housekeeping/ Documents saying that the
LGU passed the Seal of Good Housekeeping
• One (1) valid government issued ID of the authorized representative
b. Government Owned and Controlled Corporation (GOCC)
c. National Government Agency or Instrumentalities
• Authorization letter for opening an account and/or disburse funds authorized by
Department of Finance (DOF) / Bureau of Treasury (BTr)
• One (1) valid government issued ID of the authorized representative
 E-SABONG OPERATOR
• Company profile;
• Detailed location sketch of company office;
• SEC Registration
• Articles of Incorporation
• Notarized Secretary’s Certificate
• Latest General Information Sheet (GIS) duly filed with SEC with UBO declaration
• Mayor’s Permit/Business Permit/Municipal License for the relevant gaming activities from the
location of the company office;
 • List of websites/domains and mobile applications
• BIR Registration Certificate;
• PAGCOR license
• Latest Audited Financial Statement or Annual Return
• AML Registration Certificate

*Additional requirements may be required after initial assessment of the initial documents.

F. ADDITIONAL DOCUMENTS NEEDED

No Documents Needed

1 Secondary Certificate of Registration or License to operate

2 Latest Audited Financial Statement or Annual Return

G. CONFIRMATION

We confirm that the above information is accurate and that the Institution is fully compliant with applicable AML/CTF
laws and regulations. Further, we commit to comply with the GXI’s accreditation procedures and provide all the
applicable documents listed above.

PETER PANTILLA
Name

Position FOUNDER / OWNER

peter@sofaree.com
E-mail Address

Telephone No. 09499899460

Signature and Date

For GXI's Use Only

Reviewed by: _______________Date: ____________________

(Name and signature of Account Manager)