th* The wolfsberg Group Anti-Money Laundering euestionnai re 2or4/English

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Group

Financial Institution Name: AYEYARWADY BANK LIMITED

This questionnaire acts as an aid to firms conducting due diligence and shoutd not be relied on
exclusively
or excessively. Firms may use this questionnaire atongside their own poticies and procedures in
provide a basis for conducting client due diligence in a manner consistent with the order to
risk profip presented
by the client. The responsibility for ensuring adequate due diligence, which may includ'e independent .

verification or follow up of the answers and documents providdd, remains the responsibility of
the firm
using th is q uestion na i re.

IfyouansWer'.no,,toanyquestion,aooitidatthe
end of the questionnaire,
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1. Is the AML compliance program approved by the flrs board or a Yc No
senior committee?
2. Does the FI have a legal and regulatory compliance program Yc No
that includes a designated officer that is responsible for
coordinating and overseeinq the AML framework?
3. Has the FI developed written policies documenting the Yo No
processes that they have in place to prevent, detect and report
suspicious transactions?
4. In addition to inspections by the government Yo No
supervisors/regulators, does the FI client have an internal audit
function or other independent third party that assesses AML
policies and practices on a regular basis? -
5. Does the FI have a policy prohibiting accounts/relationships Yc No
with shell banks? (A shell bank is defined as a bank
incorporated in a jurisdiction in which it has no physical
presence and which is unaffiliated with a regulated financial
group.)
6. Does the FI have policies to reasonabty ensureTtrat tfre! wN
Yo No
not conduct transactions with or on behalf of shell banks
through anv of its accounts or products?
7. Does the FI have policies covering relationships with polrtically
Yo No
Exposed Persons (PEp's), their fAmily and close associates?
B. Does the FI have record retention proceo@
Yr No
applicable law?
9. Are the FI's AML policies an Yo No
branches and subsidiaries of the FI both in ihe'home country
and in locations outside of that iurisdiction?

The wolfsberg Group consistl of_the following leading international financial institutions:
Banco santander, Bank of Tokyo-Mitsubishi
U.FJ, Barclays, citigroup, Credit Suisse, Deutiche Bank, Goldman Sachs, HSBc,
Jp Morgan chase, iociet6 G6n6rale and uBS which
aim to develop financial services industry standards, and related products,'forknow t;rr
Counter Terrorist Financing policies,
Crri;;;r; Anti-Money Laundering and
 tks The wolfsberg Group Anti-Money Laundering euestionnaire 2014/English

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10. Does the FI have a risk-based assessmena of its cr.rstomei base Yc No
and their transactions?
11. Does the FI determine the appropriate level oT enharrced due Yc No
diligence necessary for those categories of customers and
transactions that the FI has reason to believe pose a
. heightened rigk of illicit activities at or throuoh the FI?

12. Has the FI implemented processes for the identification of thoseYo No

customers on whose behalf it maintains or operates accounts or
conducts transactions?
13. Does the FI have a requirement to collect inrormation regarorng Yc
No
its customers' business activities?
14. uoes tne Fi assess its FI customers, AML policies or practices? Yc No
15. Does the FI have a process to review and, where appropriate, Yr No
update customer information relating to high risk client
information?
1o' Does the Fi have procedures to establish a record for each new Yo No
customer noting their respective identification documents and
'Knqw Your Customer' information?
17. Does the FI complete a risk-based assessment to understand Yo No
the normal and ex fq4sactions of its customers?

18. Does the Fi have poticies or practicesEi tnElEEntinGil6n ano Yc No

reporting of transactions that are required to be reported to the
authorities?
19. where cash transaction reporting is mm Yc No
have procedures to identify transactions structured to avoid
such obligations?
20. Does the FI screen customers and tffi Yt No
persons, entities or countries issued by government/competent
authorities?
21. Does the FI have poricies to reasona6@ Yc No
operates with correspondent banks that possess licenses to
operate in their countries of oriqin?
22. Does the FI adhere to the worrsuerg@ Yo No
and the appropriate usage of the SWIFT MT 202/2OZCOV and
ffimessage fqrmats?l
,i,y,
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23. Does the FI have a monitoring program for unusuii anO Yo No
potentially suspicious activity that covers funds transfers and
monetary instruments such as travelers checks, money orders,
etc?

I The four payment message standards to be observed are: i) FIs should not omit,
delete, or alter ihformation in payment messages or orders for the purpose of
avoiding detection of that information by any other FI in the payment process;
ii) FIs should not use any particular payment message for the purpose of avoiding
detection of information by any other FI in the payment process; iii) subject
to applicable laws, FIs should cooperate as fully as practicabte with other Fls in the
payment process when requesting to provide information about
the parties Involved; and (iv) FIs should strongly encourage their correspondent
banks to observe
these principles, Source:

The wolfsberg Group consist: of-the following leading international financial institutions:
Banco Santander, Bank of Tokyo-Mitsubishi
UFJ, Barclays, citigroup, Credit Suisse, Deutiche Barik, Goldman sachs, HsBc,
Jp Morgan chase, iociet6 G6n6rale and UBS which
aim to develop financial services industry standards, and related produits, forknow v,irr
Counter Terrorist Financing policies,
crri""i",l Anti-Money Laundering and
 I "*r
,-

the The wolfsberg Group Anti-Money Laundering

euestionnaire 2014/Engrish
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24. Does the FI provide AML training to retevant emptoveii inli
includes:
. Identification and reporting of transactions that must be
reported to government authorities,
' Examples of different forms of money laundering involving the
FI's products and services.
. Internal policies to prevent money launderinq.
25' Does the FI retain records or its tiai@
attgndancq records and relevant traininq materials used?
26. Does the FI communicate new
existing AML related policies or practices to relevant

27. Does the Fi employ third parties to iarry out sonre or tlre
functisns of the FI?
28,If the answer to question 27 is yes, Oo@
training to relevant third parties that includes:
. Identification and reporting of transactions that must be
reported to government authorities.
' Examples of different forms of money laundering involving the
Fi's products and services.
. Internal policies to

Space for additional information:

(Please indicate which question the information is referring to.)
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Name: Mr. Than Zaw \

Title: Chief Compliance Officer ;'*l r
Signature: # -aa 7\
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The wolfsberg Group consists of the following leading international financial institutions:
Banco santander, Bank of Tokyo-Mitsubishi
u.FJ,.Barclays, c-itigroup, credit suisse, Deutiche Barik, Goldman sachs, ibgc,:p
Morgan chase, societd G6n6rale and uBs which
aim to develop financial services industry standards, and related produits, rorknow viur
Counter Terrorist Financing policies.
curior"r, Anti-Money Laundering and