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Know Your Customer:
Quick Reference Guide
Anti-Money Laundering

Understanding global
KYC differences

January 2013

Launch

Anti-Money Laundering

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 year’s 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. We’ve included details of the appropriate PwC AML
professionals in the countries featured. They would be happy to
discuss any AML issues you might have.

Anti-Money Laundering

Know Your Customer: Quick Reference Guide
Understanding global KYC differences
Record-breaking fines issued by regulators worldwide, notably in Click to return to main map
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 year’s 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 Europe
specialists. We’ve included details of the appropriate PwC AML Finland Netherlands
Austria Germany Isle ofHungary
Man Poland Switzerland
Slovakia
professionals in the countries featured. They would be happy to
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

Anti-Money Laundering

Know Your Customer: Quick Reference Guide
Understanding global KYC differences
Record-breaking fines issued by regulators worldwide, notably in Click to return to main map
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 year’s 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 Americas
specialists. We’ve included details of the appropriate PwC AML Argentina Brazil Cayman Islands Jamaica Paraguay Uruguay
professionals in the countries featured. They would be happy to
discuss any AML issues you might have. Bolivia Canada Colombia Mexico Peru USA

Anti-Money Laundering

Know Your Customer: Quick Reference Guide
Understanding global KYC differences
Record-breaking fines issued by regulators worldwide, notably in Click to return to main map
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 year’s 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 Africa
specialists. We’ve included details of the appropriate PwC AML Angola Côte d’lvoire (Ivory Coast) Gabon Kenya Zambia
professionals in the countries featured. They would be happy to
discuss any AML issues you might have. Cameroon Egypt Ghana South Africa

This looks set to continue in 2013 if regulators identify further failings in firms’ compliance with money laundering. Information about whether local regulators support the use of the risk based approach to AML. 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. They would be happy to discuss any AML issues you might have. 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. From time to time. This year’s guide has been expanded to include additional new countries and incorporates the main local AML requirements for over 74 different countries. sanctions and tax requirements. dominated the financial services landscape in 2012. . 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. notably in Click to return to main map the US and UK.Anti-Money Laundering Know Your Customer: Quick Reference Guide Understanding global KYC differences Record-breaking fines issued by regulators worldwide. We’ve included details of the appropriate PwC AML Bahrain Iraq Israel Jordan Lebanon Oman Qatar UAE professionals in the countries featured. to assist firms operating internationally in mitigating their risk. Useful links to Financial Action Task Force (‘FATF’) reports and country evaluations are also included. reporting obligations and any penalties for non compliance. There are also questions on the topic of reporting requirements within the various territories such as whom to report suspicious activity to. how to deal with Politically Exposed Persons (‘PEPs’) and whether doing business with shell banks is prohibited can all be found in our guide. you may need expert advice from AML Middle East specialists. 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. They would be happy to discuss any AML issues you might have. we have developed a Know Your Customer (‘KYC’) quick reference guide which provides quick and easy access to global AML and KYC information. dominated the financial services landscape in 2012. Information about whether local regulators support the use of the risk based approach to AML. From time to time. notably in Click to return to main map the US and UK. There are also questions on the topic of reporting requirements within the various territories such as whom to report suspicious activity to. In light of the above. you may need expert advice from AML Asia/Pacific specialists. 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. This year’s guide has been expanded to include additional new countries and incorporates the main local AML requirements for over 74 different countries. We’ve included details of the appropriate PwC AML Austrailia Australia India Malaysia Philippines Taiwan professionals in the countries featured.Anti-Money Laundering Know Your Customer: Quick Reference Guide Understanding global KYC differences Record-breaking fines issued by regulators worldwide. to assist firms operating internationally in mitigating their risk. how to deal with Politically Exposed Persons (‘PEPs’) and whether doing business with shell banks is prohibited can all be found in our guide. This looks set to continue in 2013 if regulators identify further failings in firms’ compliance with money laundering. China Indonesia New Zealand Singapore Thailand Hong Kong Japan Pakistan South Korea Vietnam . sanctions and tax requirements. The guide details many regulatory and other cultural issues which need to be addressed when doing business across territories. 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. reporting obligations and any penalties for non compliance.

high value goods etc. Q3. In what year did the relevant AML laws and regulations become effective? A1. Please include link to the regulator(s) website A3. or. (c) Non financial sector (e. Q6. and. Yes.org/external/pubs/ft/scr/2010/cr1017. each of which is a separate and independent legal entity. 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.zm Q4. responsibility or duty of care for any consequences of you or anyone else acting. Q2. (b) Other financial Services. responsible All rights reserved. A7. under which customer due diligence is not required. to clients. PricewaterhouseCoopers LLP.pwc. where available. and does not constitute professional advice. The application and impact of laws can vary widely based on the specific facts involved. Q5.boz. Are there minimum transaction thresholds.pdf Customer due diligence Q8. in reliance on the information contained in this context requires. or refraining to act. 2001 (Prohibition & Prevention of Money Laundering Act). or liable for the acts or omissions “PricewaterhouseCoopers” of any other refers the member firm nor can it control to the network exercise PricewaterhouseCoopers International Limited.O Box 30942. “PwC” refers to the network of member firms of PricewaterhouseCoopers International Limited (PwCIL). 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. employees and © 2013 PwC.com Thabo Mbeki Road January 2013 Tel: +260 211 256471/2 P. Lusaka. as the agents do not accept or assume any liability. beyond the FATF recommendations and local legislation? Please include link to website. to the extent permitted by law. You should not act upon the information contained in this publication without obtaining specific professional advice. . Each member firm is a separate legal entity and does not act as agent of PwCIL or any other member firm. No. Who is the regulator for AML controls for: (a) Banking.g. Is there a requirement to retrospectively verify the identity of customers before the date the new AML regime was introduced? A5. what are the various thresholds in place? A8.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. The Design Group 21383 (01/13) of member of another firms firm’s member of  professional judgment or bind another member firm or PwCIL in any way. casinos.pia. Is there any practical guidance provided to firms by public authorities regarding AML requirements. All rights reserved.zm/ Pensions and Insurance Authority – www. Is a risk based approach approved by the local regulator(s)? A6. PwCIL does not provide any services on it. There are no minimum transaction thresholds. .imf.x. Q7. Not for further distribution without the permission of PwC. This publication has been prepared for general guidance on matters of interest for the personal use of the reader. its members. A4. under which customer due diligence is not required? If Yes. No member firm is © 2009 PricewaterhouseCoopers. please find a link to a relevant report (if publicly available). N/A. what were the requirements of the previous AML regime? A2. publication or forindividual member any decision basedfirms of the PwC network.org. 2374 Last updated: Email: nasir. Bank of Zambia . 2010 (Prohibition & Prevention of Money Laundering (Amendment) Act # 44 2004 (Bank of Zambia Anti-Money Laundering Directives) and the Financial Intelligence Centre Act 2010.ali@zm. Zambia General Q1.).http://www. No. http://www. No representation or warranty (express or implied) is given as to the accuracy or completeness of the information contained in this publication.y. If the AML laws and/or regulations became effective in the last 2 years.

and j) suspicious deposits. the identity of any person acting on behalf of the customer. including evidence that such person is properly authorised to act in that capacity. the source of funds and a copy of the last available accounts where applicable. indication of the expected turnover. what are the requirements around independent verification or authentication? A10. such as the ownership of publicly held corporations.Questions and Answers: ‘Know Your Customer’ quick reference guide Country by country comparison of high level Know Your Customer and Anti-Money Laundering information Q9. f) suspicious activity in credit transactions. the corporate name. In what circumstances are reduced/simplified due diligence arrangements available? A12. the reason for the account being opened. c) suspicious cash transactions. In the case of a foreign national. beneficial owners and management i. b) suspicious customer identification circumstances. or refraining to act. the circumstances are to be determined by the regulated institution and approved by Bank of Zambia. i) suspicious investment activity. proof of incorporation or similar evidence of legal status and legal form. identities of directors. obtain Certificate of Incorporation or equivalent and details of the registered office/place of business.e. in which such identification and verification is not necessary.  . 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. In the case of trusts and internet banking. For regulated institutions. in reliance on the information contained in this publication or for any decision based on it. Individuals: A Zambian national has to present a national registration card or a valid passport or driving licence. © 2009 PricewaterhouseCoopers. the name address of the trustees. The Financial Intelligence Centre Act stipulates that: A reporting entity shall. Q12. No representation or warranty (express or implied) is given as to the accuracy or completeness of the information contained in this publication. an issued visa). In what circumstances are enhanced customer due diligence measures required? A13. The application and impact of laws can vary widely based on the specific facts involved. g) suspicious commercial account activity. Legal entities: Verify the identity of the directors. 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. its members. the settler and the beneficiary of express trusts. All rights reserved. vary or otherwise control the arrangement d) In addition to the identity of a customer. What are the high level requirements around beneficial ownership (identification and verification)? A11. it should make a report to the AML Investigations Unit. . Where copies of identification documentation are provided. h) suspicious trade financing transactions. d) suspicious wire transfer transactions. Q10. each of which is a separate and independent legal entity. and does not constitute professional advice. and. responsibility or duty of care for any consequences of you or anyone else acting. to the extent permitted by law. 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. and any other parties with the authority to manage. c) For legal arrangement. You should not act upon the information contained in this publication without obtaining specific professional advice. employees and agents do not accept or assume any liability. provisions of governing the authority to bind the legal person. PricewaterhouseCoopers LLP. e) suspicious safe deposit area activity. “PricewaterhouseCoopers” refers to the network of member firms of PricewaterhouseCoopers International Limited. This publication has been prepared for general guidance on matters of interest for the personal use of the reader. e) Information on the intended purpose and nature of each business relationship. details of the nature of their business. Also in circumstances of suspicion as stated below: a) suspicious customer behaviour. a national registration card and a valid passport (and where applicable. the head office address. Q13. Q11. and such information as is necessary to understand the ownership and the control of the legal person. b) For a legal entity. and f) Sufficient information about the nature and business of the customer to permit the reporting entity to fulfil its obligations under the Act. Certification of relevant identification copies by a Commissioner of Oaths. What are the high level requirements for verification of customer identification information (individuals and legal entities)? A9.

international wire transfers. Q17. which may take such steps as it believes to be appropriate to accomplish purposes of the Act. Information on the volume of SARs is not publicly available. Q16. A19. or is related to or linked to. 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. A18. 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. its members. institutions must advise its supervisory authority. The circumstances are to be determined by the regulated institution and approved by Bank of Zambia. or refraining to act. Are there any de-minimis thresholds below which transactions do not need to be reported? A21. responsibility or duty of care for any consequences of you or anyone else acting. Q15. Where the laws of the country in which its branch or majority owned subsidiary is situated prevent compliance with the obligations stipulated. to the extent permitted by law. Financial institutions are obliged to report where there is suspicion or reasonable grounds to suspect that any property is the proceeds of crime. In what circumstances is additional due diligence required for non face-to-face transactions and/or relationships? A17. Suspicious Activity reports are made to the Anti Money Laundering Investigations Unit and for financial institutions the Financial Intelligence Centre Q19. “PricewaterhouseCoopers” refers to the network of member firms of PricewaterhouseCoopers International Limited. Q21. financing of terrorism and any other serious offence. What enhanced due diligence must be performed for correspondent banking relationships (cross-border banking and similar relationships)? A15. No there is no obligation to report anything more than suspicious transactions – please see response to Q13. 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. Reporting Q18. and. © 2009 PricewaterhouseCoopers. Are there any obligations to report anything more than suspicious transactions e. Financial Intelligence Centre Act states that where any business relationship or execution of transactions is made with a customer that is not physically present. terrorist acts or by terrorist organisations or persons who financed terrorism.? A20. Yes. You should not act upon the information contained in this publication without obtaining specific professional advice. each of which is a separate and independent legal entity. in reliance on the information contained in this publication or for any decision based on it. unusual transactions. In what circumstances is additional due diligence required for Politically Exposed Persons (‘PEPs’)? A14. No representation or warranty (express or implied) is given as to the accuracy or completeness of the information contained in this publication.g. or is to be used for terrorism. What was the volume of SARs made to the authorities in the most recent year? Please state the GDP for the equivalent year. PricewaterhouseCoopers LLP. The application and impact of laws can vary widely based on the specific facts involved. the following is required for purposes of identification: a) Take adequate measures to address the specific risk of money laundering.  . To whom are Suspicious Activity Reports (SARs) made? Please include a link to their website. and does not constitute professional advice.Questions and Answers: ‘Know Your Customer’ quick reference guide Country by country comparison of high level Know Your Customer and Anti-Money Laundering information Q14. employees and agents do not accept or assume any liability. The standard due diligence procedure of identification and verification applies for non face-to-face transactions and/or relationships. All rights reserved. No . or confirmatory certification from financial institutions or other documentary evidence or measure may be prescribed. cash transactions above a certain threshold. Are relationships with shell banks specifically prohibited? A16. Q20. other transactions etc. This publication has been prepared for general guidance on matters of interest for the personal use of the reader.

Q23. tax and advisory services. A person who intentionally fails to submit a report to the Centre commits an offence and is liable. has been or is about to be committed. financing of terrorism or any other serious offence. shall be guilty of an offence and shall be liable. tipping off? A22. All rights reserved. responsibility or duty the information of care in contained forthis anypublication consequences of you without or anyone obtaining else professional specific acting. to a fine not exceeding one hundred and thirty-nine thousand penalty units (approximately ZMK25.does not constitute professional PricewaterhouseCoopers LLP. advice. or refraining to act. legal  any liability.020.Questions and Answers: ‘Know Your Customer’ quick reference guide Country by country comparison of high level Know Your Customer and Anti-Money Laundering information Q22. “PricewaterhouseCoopers” refers to the network of member firms of .000) or to imprisonment for a period not exceeding seven years. matters of interest the extent only.000 . people who are committed to delivering quality in assurance.g.000) or to imprisonment for a term not exceeding five years or to both.000. on to and. divulges that fact or information to another person. without lawful authority. in thisofpublication each which is a or for any and separate decision based on independent it. Tell us what matters to you and find out more by visiting us at This publication has been prepared for general guidance on matters of interest for the personal use of the reader. 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.000) or to imprisonment for a period not exceeding five years. You should its members. You should not act upon the information www. in reliance onorthe representation information warranty contained (express in this or implied) is given as publication or for any decision based on it. gives any officer or employee of the regulated institution reasonable grounds to believe that a money laundering offence is being. Q25. Are there any requirements (legal or regulatory) to use automated Suspicious Transaction monitoring technology? A23. No Q24. Does the local legislation allow transactions to be monitored outside the jurisdiction? A25. 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. Any person who knows or suspects that an investigation into money laundering has been. Is there a requirement to obtain authority to proceed with a current/ongoing transaction that is identified as suspicious? A24. upon conviction to a fine not exceeding seven hundred thousand penalty units (approx ZMK126.pwc. The regulated institution shall report to the AML Investigations Unit where the identity of the persons involved.to Noact. not act employees upon and agents do not accept or assume any liability. upon conviction.000. and does not constitute professional advice. or refraining advice. the circumstances of any business transaction or where any cash transaction. PwC does do not accept or assume PricewaterhouseCoopers International Limited. Are there any penalties for non compliance with reporting requirements e. responsibility or duty of care for any consequences of you or anyone else acting.byand permitted law. 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. or to both. and. We’re a network of firms in 158 countries with more than 180. Although the local legislation does not specify this. to the accuracy or completeness of the information contained in this publication. contained in this publication without obtaining specific professional advice. or to both. entity. No representation or warranty (express This publication or implied) is given as to the accuracy or completeness has been contained of the information prepared for general in this guidance publication. The application and impact of laws can vary widely based on the specific facts involved. is being or is about to be conducted. PwC helps organisations and individuals create the value they’re looking for. in reliance on the information contained © 2009 PricewaterhouseCoopers. to the extent permitted by law.com.

za/ Q4. employees and © 2013 PwC.www. The Financial Intelligence Centre Act. Section 28 and Section 51 of FICA – the cash threshold reporting provisions . The Design Group 21383 (01/13) of member of another firms firm’s member of  professional judgment or bind another member firm or PwCIL in any way.melnick@za. Please include link to the regulator(s) website A3. Is a risk based approach approved by the local regulator(s)? A6.fsb.Estate Agency Affairs Board . Accountable institutions are expected to apply a risk-based approach inter alia in respect of customer relationships. These can be at https://www. Is there a requirement to retrospectively verify the identity of customers before the date the new AML regime was introduced? A5. An accountable institution that had an established business relationship with a client before the FIC Act took effect.co.www.org. it is covered in Guidance Note 1 issued by the FIC in April 2004. 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. to provide for administrative sanctions and to make further provision for offences. Q7. publication or forindividual member any decision basedfirms of the PwC network. unless it has taken the prescribed steps to establish and verify the identity of the client. in reliance on the information contained in this context requires.fic. 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.pwc. The purpose of the amendments are inter alia to clarify the roles and responsibilities of supervisory bodies. to clients. Not for further distribution without the permission of PwC. or. where available. responsible All rights reserved. or refraining to act. (b) Other financial Services.za/ Real Estate . beyond the FATF recommendations and local legislation? Please include link to website.com Sunninghill. Yes .www. or liable for the acts or omissions “PricewaterhouseCoopers” of any other refers the member firm nor can it control to the network exercise PricewaterhouseCoopers International Limited.aspx?id=15 Q5. A4.fic. In what year did the relevant AML laws and regulations become effective? A1.org.za/ c) Casinos . The Financial Intelligence Centre Act has issued various guidance notes with regards to AML requirements. high value goods etc. Is there any practical guidance provided to firms by public authorities regarding AML requirements. If the AML laws and/or regulations became effective in the last 2 years. its members.za/SiteContent/ContentPage.lssa. Q6. 11 of 2008) was released in August 2008 and became effective on 1 December 2010.g. responsibility or duty of care for any consequences of you or anyone else acting.eaab. No member firm is © 2009 PricewaterhouseCoopers.National Gambling Board . Who is the regulator for AML controls for: (a) Banking. PricewaterhouseCoopers LLP. 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. AML laws The Prevention of Organised Crime Act No.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. what were the requirements of the previous AML regime? A2. Each member firm is a separate legal entity and does not act as agent of PwCIL or any other member firm. 38 of 2001 (FICA) was enacted in 2001. Industry regulators and supervisory bodies provide oversight within the various industries a) South African Reserve Bank . Yes – although the FIC Act.gov.came into operation in October 2010. “PwC” refers to the network of member firms of PricewaterhouseCoopers International Limited (PwCIL). and does not constitute professional advice.Law Society . 2157. The main amendments to FICA do not detract from the original AML requirements but rather clarify areas in the law. please find a link to a relevant report (if publicly available). This publication has been prepared for general guidance on matters of interest for the personal use of the reader. each of which is a separate and independent legal entity. 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. 2008 (Act No.za) fulfils an overarching regulatory role for combating money laundering and terrorist financing.za/ b) Financial Services Board .org. 38 of 2001 and the regulations do not expressly make reference to a risk-based approach. South Africa January 2013 Tel: +27 11 797 4064 General Q1.co. Q3. and. (c) Non financial sector (e. . may not conclude a transaction in the course of that business relationship.resbank.Questions and Answers: ‘Know Your Customer’ quick reference guide Country by country comparison of high level Know Your Customer and Anti-Money Laundering information South Africa Key contact: Roy Melnick Postal address: 2 Eglin Road Last updated: Email: roy. authorise the Financial Intelligence Centre and supervisory bodies to conduct inspections.www.gov. to the extent permitted by law. PwCIL does not provide any services on it.za/ Attorneys . No representation or warranty (express or implied) is given as to the accuracy or completeness of the information contained in this publication. 121 of 1998. The Financial Intelligence Centre Amendment Act. as the agents do not accept or assume any liability. Q2.ngb.). . The Financial Intelligence Centre (www. casinos.www. All rights reserved.

clients that held accounts with them at the time that the law became operational. responsibility or duty of care for any consequences of you or anyone else acting. Where copies of identification documentation are provided.an accountable institution must verify the full name. Questions Q6. may not conclude a transaction in the course of that business relationship. You should not act upon the information contained in this publication without obtaining specific professional advice. 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). “PricewaterhouseCoopers” refers to the network of member firms of . in reliance on the information contained in this publication or for any decision based on it. its members.html contained in this publication without obtaining specific professional advice. the verification methods used must be as effective as those that are applied to customers who are available for an interview. Accountable institutions are expected to apply a risk-based approach inter alia in respect of customer relationships. The FIC Act regulations contain the detail of other requirements pertaining to these as well as other persons/entities (foreign nationals. unless it has taken the prescribed steps to establish and verify the identity of the client. An accountable institution that had an established business relationship with a client before the FIC Act took effect. 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. and does not constitute professional advice. non-face-to-face verification. please find a link to a relevant report (if publicly available). Is a risk and Answers: based approach approved by the local regulator(s)? ‘Know A6. the particulars of every member and every representative of a close corporation must be obtained. In respect of trusts. High-risk client types and high risk transactions and services warrant enhanced due diligence procedures. Guidance is also provided on non face-to-face verification by the FIC. must be established and verified. date of birth and identity number of a natural person to an identification document of that person. a utility bill stating the residential address of the individual). Q13. In what circumstances are enhanced customer due diligence measures required? A13. and each authorised person. registration number. However the law does make provision for certain exemptions where a reduced level of due diligence is permitted. “PricewaterhouseCoopers” refers to the network of member firms of Customer due diligence PricewaterhouseCoopers International Limited. A7. the information http://www. foreign companies. registered address. © 2009 PricewaterhouseCoopers. the identity of the founder. The residential address must be compared to information that can be used for verification purposes (e. what are the requirements around independent verification or authentication? A10. correspondent banks. These exemptions form part of the FIC Act regulations and affect various industries. The exemptions. to the extent permitted by law.  Q8. the level of due diligence is simplified for low risk clients or in respect of existing clients who are applying for different products. contain detail of the circumstances under which reduced or simplified due diligence may be applied. 38 of 2001 and the regulations do not expressly make reference to a risk-based approach. This publication has been prepared for general guidance on matters of interest for the personal use of the reader.Due diligence is always required for all client relationships and single transactions.g. it is covered in Guidance Note 1 issued by the FIC in April 2004. .org/topics/mutualevaluations/documents/mutualevaluationofsouthafrica. money service businesses. Individuals (SA residents) . professional published on the You should 2 ndupon not act of March 2008. 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. trusts. which form part of the FIC Act regulations. partnerships and close corporations. irrespective of the value involved. In respect of PEPs. employees and agents do not accept or assume any liability. trading name and the address of the entity as well as the identity of the manager of the company. Clients are given a risk-rating based on various risk factors. Q9. 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. What are the high level requirements around beneficial ownership (identification and verification)? A11. agents. Q12. No representation or warranty (express or implied) is given as to the accuracy or completeness of the information contained in this publication. All rights reserved. All rights reserved. Legal entities – the registered name. Although the FIC Act stipulates that a record must be kept of the identity document. in reliance on the information contained in this publication or for any decision based on it. and. PricewaterhouseCoopers LLP. reader. © 2009 PricewaterhouseCoopers. to the extent permitted by law. or refraining to act. or if the client is acting on behalf of another person or if another person is acting on behalf of the client. andThe doesapplicable not constitutereport wasadvice. or where the original has been sighted by an employee of the accountable institution. enhanced due-diligence is recommended. The FICA Guidance notes state that accountable institutions should follow a risk-based approach to customer due-diligence. No representation or warranty (express or implied) is given as to the accuracy or completeness of the information contained in this publication. Q11. PricewaterhouseCoopers LLP. In terms of the guidance notes and best practices. intermediary and employee accounts. each of which is a separate and independent legal entity. The application and impact of laws can vary widely based on the specific facts involved. employees and agents do not accept or assume any liability. that the identity of the client. it does not specify the requirements pertaining to authentication. The regulations have put in place measures to determine beneficial owners in respect of entities. Country by country comparison of high level Know Your Customer and Anti-Money Laundering information Q7. No . beneficiaries and trustees must be established. 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. Are there minimum transaction thresholds. inter alia. responsibility or duty of care for any consequences of you or anyone else acting. In what circumstances are reduced/simplified due diligence arrangements available? A12.) Q10. under which customer due diligence is not required? If Yes. what are the various thresholds in place? A8. Where non face-to-face verification is accepted as a means. The FIC Act stipulates. The application and impact of laws can vary widely based on the specific facts involved.fatf-gafi. What are the high level requirements for verification of customer identification information (individuals and legal entities)? A9. Your Customer’ quick reference guide Yes – although the FIC Act. its members. . Depending on the risk profile. and. and an indication of such is made on the copy. For example. or refraining to act.

international wire transfers. You should not act upon the information contained in this publication without obtaining specific professional advice. interest for the personal use of the reader. and. A19. 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. for example.aspx Q19. Decisions concerning the additional steps to be taken in cases of a non face-to-face situation should be based on a bank’s risk framework.6 million of GDP. It is calculated without making deductions for depreciation of fabricated assets or for depletion and degradation of natural resources.  A22. employees and agents do not accept or assume any liability. a potential customer or the beneficial owner is a PEP. What enhanced due diligence must be performed for correspondent banking relationships (cross-border banking and similar relationships)? A15. Are there domestic currencies any year using single de-minimis thresholds official exchange below rates. 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. unusual transactions. Reporting Q18. 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 FICA Regulations and guidance notes provide for instances in which client information is obtained in a non face-to-face situation. This publicationTransactions below has been prepared ZAR24. https://www. shell banks). namely the correspondent banking client’s domicile.2 billion (Source: data. responsibility or duty of care for any consequences of you or anyone else acting. an alternative conversion factor is used. These are: a) Regulation 22A: Information to be reported concerning property associated with terrorist and related activities. banks “must take reasonable steps” to confirm the existence of the client and to verify the identity of the natural person involved. To whom are Suspicious Activity Reports (SARs) made? Please include a link to their website. ownership. or refraining to act. The application and impact of laws can vary widely based on the specific facts involved. dollars. the Financial Intelligence Centre Act has additional reporting requirements as contained within its Regulations. 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. banks should put in place appropriate risk management systems to determine whether a customer. management structures and business and customer base.999 for general need guidance on notofbe matters reported. its members. Are there any penalties for non compliance with reporting requirements e. a person found guilty of such an offence may be fined ZAR100 million or imprisoned for up to 15 years.g. PricewaterhouseCoopers LLP. A21. and does not constitute professional advice.worldbank. persons acting on their behalf as well as families and closely associated persons to the PEP. Q15. What was the volume of SARs made to the authorities in the most recent year? Please state the GDP for the equivalent year.org* ) This results in a ratio of 1 SAR for every USD7. and there must be specific and adequate measures to mitigate the higher risk. Guidance from the FIC defining PEPs stipulates that the bank should conduct enhanced due diligence specifically on PEPs. Volume of SARs: 2011 – 53. Q17. each of which is a separate and independent legal entity.gov. Q20.fic. in reliance on the information contained in this publication or for any decision based on it. other transactions etc. tipping off? © 2009 PricewaterhouseCoopers. In what circumstances is additional due diligence required for Politically Exposed Persons (‘PEPs’)? A14.S. In such cases. Yes. 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 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. A18.506 STR’s (FIC Annual report 2011/ 2012) GDP (in current prices): 2011 – USD 408. cash transactions above a certain threshold. to the extent permitted by law. In what circumstances is additional due diligence required for non face-to-face transactions and/or relationships? A17. Yes. No representation or warranty (express or implied) is given as to the accuracy or completeness of the information contained in this publication. Q16. Dollar figures for GDP are converted from Q21.za/Secure/Reports.g.e. . The Wolfsberg principles are referred to which set out the following risk indicators that a Bank shall consider. receipt of faxes.Questions and Answers: ‘Know Your Customer’ quick reference guide Country by country comparison of high level Know Your Customer and Anti-Money Laundering information Q14. . Are there any obligations to report anything more than suspicious transactions e. In addition to performing customer due diligence measures. Suspicious Activity Reports are submitted to the Financial Intelligence Centre (FIC). Data are in current U. to ascertain the level of due diligence it will undertake. All rights reserved. “PricewaterhouseCoopers” refers to the network of member firms of PricewaterhouseCoopers International Limited. Are relationships with shell banks specifically prohibited? A16. as they are considered high risk. Q22.? A20.

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. Does the local threshold. 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. a person found guilty of such an offence may be fined ZAR100 million or imprisoned for up to 15 years. Questions and Answers: and there must be specific and adequate measures to mitigate the higher risk. and. What was the volume of SARs made to the authorities in the most recent year? Please state the GDP for the equivalent year.gov.fic. © 2009 PricewaterhouseCoopers. and. For a few countries where the official exchange rate does not reflect the rate effectively applied to actual foreign exchange transactions. cash transactions above a certain Q25. PricewaterhouseCoopers LLP. to the extent permitted by law. In A20. Tell us what matters to you and find out more by visiting us at www. byTransactions below ZAR24. and. its members. to the extent permitted by law. employees and agents do not accept or assume any liability. Are there any obligations to report anything more than suspicious transactions e. You should not act upon the information contained in this publication without obtaining specific professional advice. Regulation example. It is calculated without making deductions for depreciation of fabricated assets or for depletion and degradation of natural resources.pwc. All rights reserved. PricewaterhouseCoopers LLP. This is confirmed by Guidance Note 4 on GDP. and does not constitute professional advice. 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. .  PwC helps organisations and individuals create the value they’re looking for.22A: Information receipt of faxes. unusual transactions.com. A19. Q20. PwC does do not accept or assume any liability.999 need not be reported. employees and agents do not accept or assume any liability.2 billion (Source: data. Yes.  . Yes. Suspicious Activity Reports are submitted to the Financial Intelligence Centre (FIC). Decisions concerning the additional steps to be taken in cases of a non face-to-face situation should be based on a bank’s risk framework. No. Your Customer’ quick reference guide Are there any de-minimis thresholds below which transactions do not need to be reported? A21. To whom are Suspicious Activity Reports (SARs) made? Please include a link to their website. ‘Know Q21.org* ) A24.g. 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. A17.toInbe reportedbusiness accepting concerning fromproperty associatedcustomers non face-to-face with terrorist andshould banks relatedapply activities. each of which is a separate and independent legal entity. Country country comparison of high level Know Your Customer and Anti-Money Laundering information Reporting Q22. Dollar figures for GDP are converted from domestic currencies using single year official exchange rates. This publication has been prepared for general guidance on matters of interest for the personal use of the reader. tax and advisory services. or refraining to act. You should not act upon the information contained in this publication without obtaining specific professional advice. Are there any penalties for non compliance with reporting requirements e.000 people who are committed to delivering quality in assurance.S. This publication has been prepared for general guidance on matters of interest only. “PricewaterhouseCoopers” refers to the network of member firms of PricewaterhouseCoopers International Limited. Suspicious Transaction Reporting. responsibility or duty of care for any consequences of you or anyone else acting. responsibility or duty of care for any consequences of you or anyone else acting. legislation international allow wire transactions transfers. of the These naturalare: person a) for involved.?outside the jurisdiction? A25. issued by the Financial Intelligence Centre on the 14 th of March 2008. * 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.za/Secure/Reports. to be monitored other transactions etc.506 STR’s (FIC Annual report 2011/ 2012) Q24. South African law only applies within the borders of the country. © 2009 PricewaterhouseCoopers. or refraining to act. in reliance on the information contained in this publication or for any decision based on it.6 byof million the Financial Intelligence Centre. No representation or warranty (express or implied) is given as to the accuracy or completeness of the information contained in this publication. in reliance on the information contained in this publication or for any decision based on it. “PricewaterhouseCoopers” refers to the network of member firms of PricewaterhouseCoopers International Limited. https://www. A22. Are there any requirements (legal or regulatory) to use automated Suspicious Transaction monitoring technology? Q19. to the extent permitted by law. No representation or warranty (express or implied) is given as to the accuracy or completeness of the information contained in this publication. Volume of SARs: 2011 – 53. No. 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. responsibility or duty of care for any consequences of you or anyone else acting.aspx Q23. Data are in current U. tipping off? Q18. dollars. No representation or warranty (express or implied) is given as to the accuracy or completeness of the information contained in this publication. cases. A18. A23. and does not constitute professional advice. or refraining to act. in reliance on the information contained in this publication or for any decision based on it.worldbank.g. each of which is a separate and independent legal entity. All rights reserved. its members. We’re a network of firms in 158 countries with more than 180. 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. an alternative conversion factor is used. Once a suspicious transaction has been reported. The FICA Regulations and guidance notes provide for instances in which client information is obtained in a non face-to-face situation. The application and impact of laws can vary widely based on the specific facts involved. .

The FRC has extensive functions and power including receiving and analysis of reports of unusual or suspicious transactions made by reporting institutions. beyond the FATF recommendations and local legislation? Please include link to website. where available. Who is the regulator for AML controls for: (a) Banking. A4.com Rahimtulla Tower. 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. However. casinos. Q3. Is a risk based approach approved by the local regulator(s)? A6. No representation or warranty (express or implied) is given as to the accuracy or completeness of the information contained in this publication. PricewaterhouseCoopers LLP. There was no AML regime per se in existence previously. 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. The Money Laundering Act provides for a Financial Reporting Center (FRC). Upper Hill Road. please find a link to a relevant report (if publicly available). the 1994 Narcotic Drugs and Psychotropic Substances Control Act prohibits concealing or transferring the proceeds of drug trafficking. No.esaamlg. 7th Floor.Questions and Answers: ‘Know Your Customer’ quick reference guide Country by country comparison of high level Know Your Customer and Anti-Money Laundering information Kenya Key contact: Martin Whitehead Postal address: Last updated: Email: martin. assumeNot anyfor furtherresponsibility liability.pdf Customer due diligence . The FRC was formally operationalised in April 2012. PwCIL does not provide any services on it. This publication has been prepared for general guidance on matters of interest for the personal use of the reader. Q4.go. Kenya General Q1. and does not constitute professional advice.g. No.). responsible All rights reserved. The Design Group 21383 (01/13) network exercise of member of another firms firm’s member of  professional judgment or bind another member firm or PwCIL in any way. . do notAllaccept rights or reserved. employees and ©agents 2013 PwC. as the context requires. A7. each of which is a separate and independent legal entity.centralbank. “PwC” of consequences refers you to orthe network anyone elseofacting.ke Q5. Q7. Yes. Is there any practical guidance provided to firms by public authorities regarding AML requirements. This regulator does not yet have a website. Each member firm is a separate legal entity and does not act as agent of PwCIL or any other member firm. 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. and. 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 Proceeds of Crime and Anti-Money Laundering Act 2009 was enacted on 11 December 2009. (c) Non financial sector (e. member firms of PricewaterhouseCoopers or refraining to act. high value goods etc.whitehead@ke. 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. 2010. (b) Other financial Services. Is there a requirement to retrospectively verify the identity of customers before the date the new AML regime was introduced? A5. The country has not been subject of a FATF Mutual Evaluation or IMF assessment exercise in the last three years. to the extent permitted by law. its members.org/userfiles/Kenya_Mutual_Evaluation_Detail_Report%282%29. Q2. what were the requirements of the previous AML regime? A2. You should not act upon the information contained in this publication without obtaining specific professional advice. publication or forindividual member any decision basedfirms of the PwC network.pwc. information contained in this or. The Central Bank of Kenya has on occasions provided guidance notes regarding AML requirements. distribution without or duty the permission of care for any of PwC. in reliance on theInternational Limited (PwCIL). No. or liable for the acts or omissions “PricewaterhouseCoopers” of any other refers the member firm nor can it control to the PricewaterhouseCoopers International Limited. The report can be found at the following link: http://www. to clients. No member firm is © 2009 PricewaterhouseCoopers. However. In what year did the relevant AML laws and regulations become effective? A1. January 2013 Tel: +254 733 333207 Nairobi. The application and impact of laws can vary widely based on the specific facts involved. www. Q6. assented on 31 December 2009 and its commencement date was on 28 June 2010. If the AML laws and/or regulations became effective in the last 2 years. Please include link to the regulator(s) website A3.

The application and impact of laws can vary widely based on the specific facts involved.pdf Country by country comparison of high level Know Your Customer and Anti-Money Laundering information Customer due diligence . All rights reserved. judges. 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. As with face-to-face verification. and d) written confirmation from the customer’s previous bank attesting to their identity and account relationship history (bank referee). making telephone contact with the applicant on an independently verified home or business number. Q13. in reliance on the information contained in this publication or for any decision based on it. and. No. d) audited financial statements for corporations. Independent means of verifying these details includes requesting sight of a recent utility bill.for telegraphic transfers and travellers cheques. None stated in local regulations or guidance. Q14. None stated in local regulations or guidance. calling their employer’s personnel department to confirm employment etc. What enhanced due diligence must be performed for correspondent banking relationships (cross-border banking and similar relationships)? A15. PricewaterhouseCoopers LLP. transaction on matters of interest underfor the personal which customeruse of due the reader. Corporates / Firms: a) Certificate of Registration. publication or for any decision based on it. commissioners of oath.000 each of which a separate andper customer independent legalper day without seeing and recording a valid identification document. Q15.  Q9.org/userfiles/Kenya_Mutual_Evaluation_Detail_Report%282%29. to the extent permitted by law. the equivalent of isUSD10. managing director. c) identity and address of the chairman. and e) where applicable. checking a local telephone directory (for businesses). and does not constitute professional advice. Where copies of identification documentation are provided. its members. c) source of income. Documents must be certified by suitable third parties and confirmation from the previous bank obtained where possible. to the extent permitted by law. identity card or driving licence. and. or the general partner and at least one limited partner for partnerships. Local guidance requires institutions to have full disclosure of beneficial owners or controlling persons behind nominee accounts. However. Kenya is a ‘Know Your Customer’ quick reference guide 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. responsibility or duty of care for any consequences of you or anyone else acting. You should not act upon the information Q16. Q10. responsibility or duty of care for any consequences of you or anyone else acting. In what circumstances are enhanced customer due diligence measures required? A13. A foreign exchange bureau should not sell foreign currency or travellers cheques in © 2009 PricewaterhouseCoopers. the procedures to check identity must ensure that a person bearing the name of the applicant exists and lives at the address provided. © 2009 PricewaterhouseCoopers. In what circumstances are reduced/simplified due diligence arrangements available? A12. This publication has been prepared for general guidance on matters of interest for the personal use of the reader. birth certificate. Yes. magistrates and certain government officials. Theand country Answers: has not been subject of a FATF Mutual Evaluation or IMF assessment exercise in the last three years. contained in this publication without obtaining specific professional advice. “PricewaterhouseCoopers” refers to the network of member firms of PricewaterhouseCoopers International Limited. Suitable third parties include advocates. A8. Individuals: a) an official record such as passport. 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. or refraining to act. please find a link to a relevant report (if publicly available). What are the high level requirements for verification of customer identification information (individuals and legal entities)? A9. . b) Board Resolution stating authority to open accounts and designating persons having signatory authority. each of which is a separate and independent legal entity. notaries public. in reliance on the information contained in this A16. Are contained in this relationships publication with shell without obtaining banks specific specifically professional prohibited? advice. its members. The application and impact of laws can vary widely based on the specific facts involved. This publicationArehasthere been prepared minimum for general guidancethresholds. employees and agents do not accept or assume any liability.esaamlg. No representation or warranty (express If Yes. verifying salary details appearing on a recent bank account statement. Questions A7. b) address verified by a referee or utility bill. Yes . All rights reserved. What are the high level requirements around beneficial ownership (identification and verification)? A11. In what circumstances is additional due diligence required for Politically Exposed Persons (‘PEPs’)? A14. Memorandum and Articles of Association. written confirmation from the customer's previous bank. and the applicant is that person he claims he is. or implied) is given as towhat are the the accuracy or various thresholds completeness in place? of the information contained in this publication.). what are the requirements around independent verification or authentication? A10. and does diligence not constitute is not required?professional advice. or with the customer’s consent. entity. Q7. or refraining to act. Q12. Certificate of Incorporation. Partnership Deed. You should not act upon the information Q8. or the principal owner for sole traders. No representation or warranty (express or implied) is given as to the accuracy or completeness of the information contained in this publication. Q11.  . PricewaterhouseCoopers LLP. employees and agents do not accept or assume any liability. None stated in local regulations or guidance. “PricewaterhouseCoopers” refers to the network of member firms of excess orInternational PricewaterhouseCoopers equal to Limited. The report can be found at the following link: http://www.

go. In what circumstances is additional due diligence required for non face-to-face transactions and/or relationships? A17. Q20.? A20. This publication has been prepared for general guidance on matters of interest only. . However this Center is yet to be set up. and. However.g.centralbank. No. to the extent permitted by law.000 people who are committed to delivering quality in assurance. or refraining to act. including telephone contact with the applicant on an independently verified home or business number. and does not constitute professional advice. Local guidance requires the following due diligence: requesting sight of a recent utility bill. You should not act upon the information contained in this publication without obtaining specific professional advice. by Country Yes. While local legislation does not allow transactions to be monitored outside the jurisdiction per se. www. in reliance on the information contained in this publication or for any decision based on it. employer’s personnel department confirming employment by verbal confirmation on a listed number (with the customer's consent). Your Customer’ quick reference guide Are relationships with shell banks specifically prohibited? A16. Are there any de-minimis thresholds below which transactions do not need to be reported? A21. The application and impact of laws can vary widely based on the specific facts involved. other transactions etc. Information on the volume of SARs is not publicly available. In addition. The Act requires monitoring on an ongoing basis all complex. We’re a network of firms in 158 countries with more than 180. and does not constitute professional advice. each of which is a separate and independent legal entity. the reporting institution is required to keep all records relating to that transaction and ensure that its reporting obligations under the Act are discharged. No. unusual. local authority tax bill. and upon suspicion. in reliance on the information contained in this publication or for any decision based on it. Q24. institution statement or checking a local telephone directory (for businesses). large or other transactions. Does the local legislation allow transactions to be monitored outside the jurisdiction? A25. Reporting Q18. “Tipping off” is considered to be an offence under the Act. A19. The Act requires that SARs are made to the Financial Reporting Center. Q21. You should not act upon the information contained in this publication without obtaining specific professional advice. to the extent permitted by law. tipping off? A22. What was the volume of SARs made to the authorities in the most recent year? Please state the GDP for the equivalent year. © 2009 PricewaterhouseCoopers. Q25. therefore all SARs are to be made to the Central Bank of Kenya. and salary details appearing on a recent bank or building society statement. the Act provides for international assistance in investigations and proceedings relating to money laundering. or refraining to act.  PwC helps organisations and individuals create the value they’re looking for. and.pwc.Questions and Answers: ‘Know Q16. . “PricewaterhouseCoopers” refers to the network of member firms of PricewaterhouseCoopers International Limited. Are there any requirements (legal or regulatory) to use automated Suspicious Transaction monitoring technology? A23.ke Q19. No representation or warranty (express or implied) is given as to the accuracy or completeness of the information contained in this publication. Are there any penalties for non compliance with reporting requirements e. unusual transactions. Are there any obligations to report anything more than suspicious transactions e. No representation or warranty (express or implied) is given as to the accuracy or completeness of the information contained in this publication. To whom are Suspicious Activity Reports (SARs) made? Please include a link to their website. it should be reported accordingly. No. employees and agents do not accept or assume any liability. PwC does do not accept or assume any liability. its members. A18. country comparison of high level Know Your Customer and Anti-Money Laundering information Q17. Q22. tax and advisory services. satisfactory evidence of personal identity can be obtained by a number of means.com. cash transactions above a certain threshold. Tell us what matters to you and find out more by visiting us at www. responsibility or duty of care for any consequences of you or anyone else acting. international wire transfers. This publication has been prepared for general guidance on matters of interest for the personal use of the reader. responsibility or duty of care for any consequences of you or anyone else acting. All rights reserved.g. Is there a requirement to obtain authority to proceed with a current/ongoing transaction that is identified as suspicious? A24. suspicious. Q23. PricewaterhouseCoopers LLP. however the applicable penalty is not stipulated.

January 2013 Tel: +233-21. employees and © 2013 PwC. Yes. Q2.com No 12 Airport City.pwc. Q6. what are the various thresholds in place? A8. and the Anti-Money Laundering Regulations 2008 (LI 1925). as the agents do not accept or assume any liability. Yes (website not available). banks are encouraged to ensure that due diligence on customers is a continuous exercise. Bank of Ghana Supervision Department (and also Security agencies and Serious Fraud Office) played the quasi-role of a centre investigating 'suspicious' transactions. casinos.g. or liable for the acts or omissions “PricewaterhouseCoopers” of any other refersthe member firm nor can it control to the network exercise PricewaterhouseCoopers International Limited. The Design Group 21383 (01/13) of member of another firms firm’s member of  professional judgment or bind another member firm or PwCIL in any way. and does not constitute professional advice. beyond the FATF recommendations and local legislation? Please include link to website. to the extent permitted by law. what were the requirements of the previous AML regime? A2. Banks were to comply with the Bank of Ghana and/or parent bank KYC policies/procedures. . Yes – equivalent of USD10. This publication has been prepared for general guidance on matters of interest for the personal use of the reader. (b) Other financial Services. Who is the regulator for AML controls for: (a) Banking. 2008. No financial intelligence centre reporting requirements. Please include link to the regulator(s) website A3. 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. each of which is a separate and independent legal entity. UNA Home. its members. and. . 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. Q4. publication or forindividual member any decision basedfirms on of it. Is there a requirement to retrospectively verify the identity of customers before the date the new AML regime was introduced? A5. in reliance on the information contained in this context requires. 761614 PMB CT42. Q7. The application and impact of laws can vary widely based on the specific facts involved. (c) Non financial sector (e. the PwC network. All rights reserved. The Anti-Money Laundering Act of 2008 (Act 749). 3rd Floor. No representation or warranty (express or implied) is given as to the accuracy or completeness of the information contained in this publication. PwCIL does not provide any services to clients. A7. A4. Not for further distribution without the permission of PwC. responsible All rights reserved. high value goods etc.Questions and Answers: ‘Know Your Customer’ quick reference guide Country by country comparison of high level Know Your Customer and Anti-Money Laundering information Ghana Key contact: Felix Addo Postal address: Last updated: Email: felix. Financial Intelligence Centre (website not available).). Ghana General Q1. Customer due diligence Q8. No member firm is © 2009 PricewaterhouseCoopers. where available. “PwC” refers to the network of member firms of PricewaterhouseCoopers International Limited (PwCIL). please find a link to a relevant report (if publicly available). The assessment body ‘GAIBA’ performed an assessment in 2009 (Source: FATF website). under which customer due diligence is not required? If Yes.761500. If the AML laws and/or regulations became effective in the last 2 years. responsibility or duty of care for any consequences of you or anyone else acting.000. Each member firm is a separate legal entity and does not act as agent of PwCIL or any other member firm.addo@gh. or. Cantonments. You should not act upon the information contained in this publication without obtaining specific professional advice. Q5. No – however. In what year did the relevant AML laws and regulations become effective? A1. or refraining to act. Are there minimum transaction thresholds. Is there any practical guidance provided to firms by public authorities regarding AML requirements. Is a risk based approach approved by the local regulator(s)? A6. Q3. PricewaterhouseCoopers LLP. Accra.

head office. No representation or warranty (express or implied) is given as to the accuracy or completeness of the information contained in this publication. The specific requirements are in process of being formalised by the Bank of Ghana. The application and impact of laws can vary widely based on the specific facts involved. certificate of business registration and commencement of business. None. telephone. each of which is a separate and independent legal entity. Individuals: Information required for individuals includes: legal name and other names. Additional due diligence is required for PEPs.  . Where copies of identification documentation are provided. what are the requirements around independent verification or authentication? A10. © 2009 PricewaterhouseCoopers. It is also a requirement to establish the PEP’s source of wealth/source of funds and the beneficial owners. In what circumstances is additional due diligence required for Politically Exposed Persons (‘PEPs’)? A14. mailing address. You should not act upon the information contained in this publication without obtaining specific professional advice. original or certified copy of regulations. the obligation is to obtain sufficient evidence of the identities of the two persons involved. and. Q15. hometown. Are relationships with shell banks specifically prohibited? A16. Q16. 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. nationality. date and place of birth. In consortium lending. location address. mailing address. In what circumstances are reduced/simplified due diligence arrangements available? A12. and does not constitute professional advice. No. nature of the business relationship and signature. When one person is acting on behalf of another. on account opening or during one-off transaction or when series of linked transactions take place. to the extent permitted by law. PricewaterhouseCoopers LLP. position held and employer's name. copy of latest auditor's report and accounts. occupation. or refraining to act. In what circumstances is additional due diligence required for non face-to-face transactions and/or relationships? A17. fax numbers. 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. Enhanced customer due diligence is required when dealing with Politically Exposed Persons ('PEPs'). in reliance on the information contained in this publication or for any decision based on it. identity documents. the lead manager/agent shall supply a confirmation letter as evidence that he has obtained the required identity. Senior Management approval must be sought before establishing a relationship with such a person. In what circumstances are enhanced customer due diligence measures required? A13. What are the high level requirements for verification of customer identification information (individuals and legal entities)? A9. All rights reserved. annual report filed with the Registrar General and names. contact phone and fax numbers. What enhanced due diligence must be performed for correspondent banking relationships (cross-border banking and similar relationships)? A15. its members.Questions and Answers: ‘Know Your Customer’ quick reference guide Country by country comparison of high level Know Your Customer and Anti-Money Laundering information Q9. What are the high level requirements around beneficial ownership (identification and verification)? A11. Q14. . Legal entities: They require a registered name. Q17. and the broker or introducer is subject to anti-money laundering rules or regulations. Q11. employees and agents do not accept or assume any liability. Q10. Q12. location of client. “PricewaterhouseCoopers” refers to the network of member firms of PricewaterhouseCoopers International Limited. This publication has been prepared for general guidance on matters of interest for the personal use of the reader. location and mailing addresses of directors. Identity shall be verified whenever a business relationship is to be established. Q13. responsibility or duty of care for any consequences of you or anyone else acting.

to the accuracy or completeness of the information contained in this publication.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. The application and impact of laws can vary widely based on the specific facts involved. not constitute professional its members. .g. international wire transfers. No. Are there any obligations to report anything more than suspicious transactions e. All rights reserved. cash transactions above a certain threshold.byand law. or refraining to act.? A20. PwC helps organisations and individuals create the value they’re looking for. Does the local legislation allow transactions to be monitored outside the jurisdiction? A25. tipping off? A22. and. To whom are Suspicious Activity Reports (SARs) made? Please include a link to their website. Information on the volume of SARs is not publicly available. Q20. Q24. Q19. PwC does do not accept or assume PricewaterhouseCoopers International Limited. © 2009 PricewaterhouseCoopers. to the extent permitted by law. Q21. No. on to the extent matters permitted of interest only. What was the volume of SARs made to the authorities in the most recent year? Please state the GDP for the equivalent year.com. Are there any penalties for non compliance with reporting requirements e. A19. advice.to Youyoushould and find notout act more upon by thevisiting us at information www.g. entity. Yes. Is there a requirement to obtain authority to proceed with a current/ongoing transaction that is identified as suspicious? A24. in any liability. constituteTell us what matters professional advice. Q22. unusual transactions. responsibility or duty the information of care in contained forthis anypublication consequences of you without or anyone obtaining else professional specific acting. No representation or warranty (express or implied) is given as to the accuracy or completeness of the information This publication has been contained prepared for in this publication. Are there any requirements (legal or regulatory) to use automated Suspicious Transaction monitoring technology? A23. legal of firms you or  ofanyone else acting. Yes . contained in this publication without obtaining specific professional advice. other transactions etc.toNoact. or refraining advice.reporting should not be limited to Suspicious Transaction Reports (STRs) alone. Are there any de-minimis thresholds below which transactions do not need to be reported? A21. Yes.pwc.does PricewaterhouseCoopers LLP. general guidance and. No. A18. tax and of the reader. Q23.Questions and Answers: ‘Know Your Customer’ quick reference guide Country by country comparison of high level Know Your Customer and Anti-Money Laundering information Reporting Q18. employees You should not actand upon agents do not accept or assume any liability. andadvisory does notservices. Q25. responsibility or duty of “PricewaterhouseCoopers” thisofpublication each which is a or for any and separate decision caretofor refers based on independent any the consequences network of member it. We’re a network of firms in 158 countries with more than 180. Financial Intelligence Centre (website not available). in reliance on the information contained . in reliance onorthe representation information warranty contained (express in thisis given as or implied) publication or for any decision based on it.

fadiga@cm. www.Questions and Answers: ‘Know Your Customer’ quick reference guide Country by country comparison of high level Know Your Customer and Anti-Money Laundering information Gabon Key contact: Douty Fadiga Postal address: P. where available. Is there any practical guidance provided to firms by public authorities regarding AML requirements. Customer due diligence Q8. please find a link to a relevant report (if publicly available). what are the various thresholds in place? A8. beyond the FATF recommendations and local legislation? Please include link to website. Q4.). as the context requires.the country has been subjected to a FATF evaluation. AML law and regulations became effective in 2005 and are only applicable for banks. individual member firms of the PwC network.an update of the customer database is required. Please include a link to the regulator(s) website A3. Each member firm is a separate legal entity and does not act as agent of PwCIL or any other member firm.com Cameroon January 2013 Tel: +237 77 93 40 70 General Q1. N/A Q3. Q2.there are no minimum transaction thresholds under which customer due diligence is not required. Q6. In what year did the relevant AML laws and regulations become effective? A1. Who is the regulator for AML controls for: (a) Banking. 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. No. Q9. Q5. Is a risk based approach approved by the local regulator(s)? A6. What are the high level requirements for verification of customer identification information (individuals and legal entities)? © 2013 PwC. (c) Non financial sector (e. A7.Box 5689 Douala. what were the requirements of the previous AML regime? A2. c) None.pwc. No member firm is responsible or liable for the acts or omissions of any other member firm nor can it control the exercise of another member firm’s professional judgment or bind another member firm or PwCIL in any way. PwCIL does not provide any services to clients. Is there a requirement to retrospectively verify the identity of customers before the date the new AML regime was introduced? A5. A4. 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.g. (b) Other financial Services. or. The Design Group 21383 (01/13) . Are there minimum transaction thresholds.int b) None. under which customer due diligence is not required? If Yes. No .beac. No – There is no risk based approach approved by the local regulator. Yes . but the report is not publicly available.O. high value goods etc. Not for further distribution without the permission of PwC. Yes . casinos. If the AML laws and/or regulations became effective in the last 2 years. All rights reserved. “PwC” refers to the network of member firms of PricewaterhouseCoopers International Limited (PwCIL). a) Banking Commission. Last updated: Email: d. Q7.

Reporting Q18. Yes.there are no minimum transaction thresholds under which customer due diligence is not required. Q12. Q14. In what circumstances is additional due diligence required for non face-to-face transactions and/or relationships? A17. b) Verification of the identification and the address of the professional intermediary. For a non face-to-face relationship. the verification of legal documents and legal representatives is required. Where copies of identification documentation are provided. b) for legal entities. Q19. Customer due diligence Questions and Answers: Are there minimum transaction thresholds. Q16. Customer due diligence is enhanced for unusual or suspicious activities/transactions. by No . In what circumstances are enhanced customer due diligence measures required? A13. In what circumstances is additional due diligence required for Politically Exposed Persons (‘PEPs’)? A14. The relationship must not be established if the correspondent is not compliant with AML regulation. Q15. Copies of identification documentation are only made by the bank after a visual check. Q11. The requirements are: a) Obtain information on the beneficial owner. The requirements are: a) verification of the identity and address of the customer by reference to official identity papers. None in the practice. What enhanced due diligence must be performed for correspondent banking relationships (cross-border banking and similar relationships)? A15. c) public officials require a heightened scrutiny. Q10. Q17. source of wealth and sources of funds. What are the high level requirements around beneficial ownership (identification and verification)? A11. A18. Q13. What are the high level requirements for verification of customer identification information (individuals and legal entities)? A9. ‘Know Your Customer’ quick reference guide If Yes. Independent verification is not required. What was the volume of SARs made to the authorities in the most recent year? Please state the GDP for the equivalent year. what are the various thresholds in place? A8. . what are the requirements around independent verification or authentication? A10. d) the bank must collect information to cover the following: anticipated account activity. Banks must acquire information on the compliance of their correspondent with Anti Money Laundering regulation. To whom are Suspicious Activity Reports (SARs) made? Please include a link to their website. The suspicious activity report is addressed to the National Agency for financial investigation (ANIF). the bank’s senior management may give authorisation before an account opening. The transactions in their accounts require heightened scrutiny. Country country comparison of high level Know Your Customer and Anti-Money Laundering information Q9. under which customer due diligence is not required? Q8. Are relationships with shell banks specifically prohibited? A16. For a PEP. Customer due diligence arrangements are reduced for low value transactions. In what circumstances are reduced/simplified due diligence arrangements available? A12. a bank must consider the need to perform independent verification.

Reporting Questions and Answers: ‘Know Your Customer’ quick reference guide Q18. and does not constitute professional advice. You should not act upon the information contained in this publication without obtaining specific professional advice.g. cash transactions above a certain threshold.? A20. Q21. To whom are Suspicious Activity Reports (SARs) made? Please include a link to their website. No. A18. The suspicious activity report is addressed to the National Agency for financial investigation (ANIF).pwc.000 people who are committed to delivering quality in assurance. to the extent permitted by law. responsibility or duty of care for any consequences of you or anyone else acting. . Are there any requirements (legal or regulatory) to use automated Suspicious Transaction monitoring technology? A23.g. No. other transactions etc. unusual transactions. tax and advisory services. A19. No representation or warranty (express or implied) is given as to the accuracy or completeness of the information contained in this publication. Q25. Does the local legislation allow transactions to be monitored outside the jurisdiction? A25. Is there a requirement to obtain authority to proceed with a current/ongoing transaction that is identified as suspicious? A24. and. Q22. Are there any de-minimis thresholds below which transactions do not need to be reported? A21. Country by country comparison of high level Know Your Customer and Anti-Money Laundering information Q19. Tell us what matters to you and find out more by visiting us at www. Are there any obligations to report anything more than suspicious transactions e. There is an obligation to report on transaction where the identity of the beneficiary or the originator is suspicious. What was the volume of SARs made to the authorities in the most recent year? Please state the GDP for the equivalent year. We’re a network of firms in 158 countries with more than 180. in reliance on the information contained in this publication or for any decision based on it. tipping off? A22. PwC helps organisations and individuals create the value they’re looking for. Q20. Yes. Q23. international wire transfers. or refraining to act. Are there any penalties for non compliance with reporting requirements e. PwC does do not accept or assume any liability. Q24. No. Information on the volume of SARs is not publicly available. No. This publication has been prepared for general guidance on matters of interest only.com.

agents do notAll rightsor accept reserved.cbe. Yes.Law # 80 for year 2002. No representation or warranty (express or implied) is given as to the accuracy or completeness of the information contained in this publication.pwc. In what year did the relevant AML laws and regulations become effective? A1. what were the requirements of the previous AML regime? A2. New January 2013 Tel: +1 (0) 876 932 8335 Cairo 11835. A7. This publication has been prepared for general guidance on matters of interest for the personal use of the reader. as the context requires. member firms of PricewaterhouseCoopers or refraining to act. c) Non financial sector: Governed by the “Anti Money Laundering Law”. where available.com Plot no 211. Who is the regulator for AML controls for: (a) Banking. employees and © 2013 PwC. Q2. information contained in this or. 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. Customer due diligence Q8. “PwC” of consequences refers you toor the network anyone elseofacting. beyond the FATF recommendations and local legislation? Please include link to website. PwCIL does not provide any services on it. casinos.diab@eg. high value goods etc. a) b) Banking: CBE (Central Bank of Egypt): www. Q4. Is a risk based approach approved by the local regulator(s)? A6.g. each of which is a separate and independent legal entity. 2002. N/A. or liable for the acts or omissions “PricewaterhouseCoopers” of any other refers the member firm nor can it control to the PricewaterhouseCoopers International Limited. Please include link to the regulator(s) website A3. However. No. and. You should not act upon the information contained in this publication without obtaining specific professional advice.Questions and Answers: ‘Know Your Customer’ quick reference guide Country by country comparison of high level Know Your Customer and Anti-Money Laundering information Egypt Key contact: Nabil Diab Postal address: Last updated: Email: nabil. Q6. The application and impact of laws can vary widely based on the specific facts involved. There is the only the “Anti Money Laundering Law” .). Is there any practical guidance provided to firms by public authorities regarding AML requirements. publication or forindividual member any decision basedfirms of the PwC network. please find a link to a relevant report (if publicly available). (c) Non financial sector (e. . Q5.Law # 80 for year 2002. and does not constitute professional advice.eg/ Other financial Services: It depends on the nature of the financial services (e. Each member firm is a separate legal entity and does not act as agent of PwCIL or any other member firm. distribution without or duty the permission of care for any of PwC. PricewaterhouseCoopers LLP. responsible All rights reserved. Insurance companies are regulated by the EISA (Egyptian Insurance Supervisory Authority). Q7. The Design Group 21383 (01/13) network exercise of member of another firms firm’s member of  professional judgment or bind another member firm or PwCIL in any way. in reliance on the International Limited (PwCIL). Q3. A4. If the AML laws and/or regulations became effective in the last 2 years. No member firm is © 2009 PricewaterhouseCoopers. to clients. Is there a requirement to retrospectively verify the identity of customers before the date the new AML regime was introduced? A5. all of the “non-banking “financial services providers are governed and regulated by the EFSA (Egyptian Financial Supervisory Authority). its members. (b) Other financial Services.org. to the extent permitted by law. 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. assumeNot anyfor furtherresponsibility liability. under which customer due diligence is not required? If Yes. No. Second Sector. PO Box 170 New Cairo General Q1.g. Egypt. Are there minimum transaction thresholds. City Center. what are the various thresholds in place? .

even if the transaction is conducted via another natural or legal person acting as a trustee. You should not act upon the information contained in this publication without obtaining specific professional advice. Country by country comparison of high level Know Your Customer and Anti-Money Laundering information Customer due diligence Q8. employees and . responsibility or duty of care for any consequences of you or anyone else acting. Q12. Q7. This should be clearly noted in the Commercial Register of the company and also show the authorised signatories of the company. and. Each natural or legal person having a real interest in any of the activities of financial institutions. address and date of birth. Where copies of identification documentation are provided.  A9. to the extent permitted by law. what are the various thresholds in place? . In what circumstances is additional due diligence required for non face-to-face transactions and/or relationships? A17. Corporates: should obtain full name. You should not act upon the information contained in this publication without obtaining specific professional advice. Yes . who are identified as PEPs. publication or for any decision What are thebased highonlevel it. ideally from government-issued documents such as government identification . business address. or refraining to act. In what circumstances are reduced/simplified due diligence arrangements available? A12. The application and impact of laws can vary widely based on the specific facts involved. its members. what are the requirements around independent verification or authentication? A10. Only copies certified and stamped by governmental bodies/authorities can be relied upon by banks. All rights reserved. None stated in local regulations or guidance. passport and weapon licence that includes the customer's full name and photograph.g. and does not constitute professional advice. None stated in local regulations or guidance. What are the high level requirements around beneficial ownership (identification and verification)? A11.the law states that financial institutions and the other entities shall take special customer due diligence measures when dealing with customers. PricewaterhouseCoopers LLP. Q15. under which customer due diligence is not required? If Yes. insurance or capital markets) it should provide confirmation of the company’s listing on the regulated market or a copy of the company’s Certificate of Incorporation. Q11. None stated in local regulations or guidance. No. This publication has been prepared for general guidance on matters of interest for the personal use of the reader. Questions and Answers: ‘Know A7. No representation or warranty (express or implied) is given as to the accuracy or completeness of the information contained in this publication. Commercial Register copy. names of all directors and beneficial owners. requirements for verification of customer identification information (individuals and legal entities)? © 2009 PricewaterhouseCoopers. No representation or warranty (express or implied) is given as to the accuracy or completeness of the information contained in this publication. those who act on their behalf and the real beneficiary. should provide documentation to verify identity. Q10. employees and agents do not accept or assume any liability. Q13. Copies of documents should be authenticated by a banks' senior staff after reviewing and verifying the original documents. its members. PricewaterhouseCoopers LLP. and does not constitute professional advice. and additionally for private companies. in reliance on the information contained in this Q9. Are there minimum transaction thresholds. In what circumstances is additional due diligence required for Politically Exposed Persons (‘PEPs’)? A14. Q17. No. Q16. In what circumstances are enhanced customer due diligence measures required? A13. The application and impact of laws can vary widely based on the specific facts involved. “PricewaterhouseCoopers” refers to the network of member firms of PricewaterhouseCoopers International Limited. A6. No. a proxy or under any other capacity. and. please find a link to a relevant report (if publicly available). and either address or date of birth. This publication has been prepared for general guidance on matters of interest for the personal use of the reader. Q14. . Are relationships with shell banks specifically prohibited? A16. None stated in local regulations or guidance. Individuals: should obtain name. Your Customer’ quick reference guide No. each of which is a separate and independent legal entity. If the company is regulated (e. A8. What enhanced due diligence must be performed for correspondent banking relationships (cross-border banking and similar relationships)? A15. 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. to the extent permitted by law. Authenticated copies from attorneys or other third parties are not accepted unless original copies are obtained.

g. PwC helps organisations and individuals create the value they’re looking for. No. Information on the volume of SARs is not publicly available. unusual transactions. Tell us what matters to you and find out more by visiting us at This publication has been prepared for general guidance on matters of interest for the personal use of the reader. Q22. Q23. entity.com.? A20.pwc. people who are committed to delivering quality in assurance. Yes . Q24. Yes . contained in this publication without obtaining specific professional advice. What was the volume of SARs made to the authorities in the most recent year? Please state the GDP for the equivalent year. Are there any penalties for non compliance with reporting requirements e. other transactions etc. specific or refraining professional advice. Q20. Is there a requirement to obtain authority to proceed with a current/ongoing transaction that is identified as suspicious? A24.Law # 80 for year 2002).byand permitted law. responsibility or duty the information of care for contained anypublication in this consequences of you without or anyone obtaining else acting.does not constitute professional PricewaterhouseCoopers advice. We’re a network of firms in 158 countries with more than 180. tipping off? A22.000 . Q21. Q19. in reliance onorthe representation information warranty contained (express in thisis given as or implied) publication or for any decision based on it. to the accuracy or completeness of the information contained in this publication.as stated in the Egyptian AML Law (Anti Money Laundering Law . © 2009 PricewaterhouseCoopers. or refraining to act. international wire transfers.toNo act. and does not constitute professional advice. legal of firms you or  of anyone else acting. No. No. Are there any de-minimis thresholds below which transactions do not need to be reported? A21. not act employees upon and agents do not accept or assume any liability.as stated in the Egyptian AML Law (Anti Money Laundering Law .Law # 80 for year 2002). tax and advisory services. A18. Q25. The application and impact of laws can vary widely based on the specific facts involved. Are there any requirements (legal or regulatory) to use automated Suspicious Transaction monitoring technology? A23. and. cash transactions above a certain threshold.g. LLP. PwC does do not accept or assume any liability. You should not act upon the information www. Yes. All rights reserved.Questions and Answers: ‘Know Your Customer’ quick reference guide Country by country comparison of high level Know Your Customer and Anti-Money Laundering information Reporting Q18. matters of interest the extent only. to the extent permitted by law. SARs are made directly to regulators as specified in Q3 above. A19. each which is a or for anyand separate of caretofor decision theany based on independent consequences network of member it. on to and. No representation or warranty (express This publication or implied) is given as to the accuracy or completeness has been contained of the information prepared for general in this guidance publication. Does the local legislation allow transactions to be monitored outside the jurisdiction? A25. Are there any obligations to report anything more than suspicious transactions e. To whom are Suspicious Activity Reports (SARs) made? Please include a link to their website. in reliance on the information contained . its You should members. responsibility or duty refers “PricewaterhouseCoopers” in thisofpublication PricewaterhouseCoopers International Limited.

No – there is no risk based approach approved by the local regulator.there are no minimum transaction thresholds under which customer due diligence is not required. Are there minimum transaction thresholds.an update of the customer database is required. No. Is a risk based approach approved by the local regulator(s)? A6. assumeNot anyfor furtherresponsibility liability. 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. what are the various thresholds in place? A8. The application and impact of laws can vary widely based on the specific facts involved. Yes .fadiga@cm. Q5. (c) Non financial sector (e.com Cameroon January 2013 Tel: +237 77 93 40 70 General Q1. N/A. 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. In what year did the relevant AML laws and regulations become effective? A1. and does not constitute professional advice. in reliance on the International Limited (PwCIL). agents do notAll rightsor accept reserved. distribution without or duty the permission of care for any of PwC.g. No representation or warranty (express or implied) is given as to the accuracy or completeness of the information contained in this publication. PricewaterhouseCoopers LLP. under which customer due diligence is not required? If Yes. No . Q7. member firms of PricewaterhouseCoopers or refraining to act. The Design Group 21383 (01/13) network exercise of member of another firms of member  firm’s professional judgment or bind another member firm or PwCIL in any way. to the extent permitted by law.O. AML law and regulations became effective in 2007 and are only applicable for banks. but the report is not publicly available. where available. beyond the FATF recommendations and local legislation? Please include link to website.Box 5689 Douala. publication or forindividual member any decision basedfirms of the PwC network. If the AML laws and/or regulations became effective in the last 2 years. its members. employees and © 2013 PwC. A4. Customer due diligence Q8. . Is there any practical guidance provided to firms by public authorities regarding AML requirements. high value goods etc. Q3. casinos. www. (b) Other financial Services. This publication has been prepared for general guidance on matters of interest for the personal use of the reader. to clients. You should not act upon the information contained in this publication without obtaining specific professional advice.the country has been subjected to a FATF evaluation. or liable for the acts or omissions “PricewaterhouseCoopers” of any other refers the member firm nor can it control to the PricewaterhouseCoopers International Limited. a) Banking Commission. Is there a requirement to retrospectively verify the identity of customers before the date the new AML regime was introduced? A5. “PwC” of consequences refers you toor the network anyone elseofacting.). Each member firm is a separate legal entity and does not act as agent of PwCIL or any other member firm. and.Questions and Answers: ‘Know Your Customer’ quick reference guide Country by country comparison of high level Know Your Customer and Anti-Money Laundering information Côte d’Ivoire (Ivory Coast) Key contact: Douty Fadiga Postal address: P. each of which is a separate and independent legal entity. A7. Yes .pwc. information contained in this or. No member firm is © 2009 PricewaterhouseCoopers. . Last updated: Email: d. Q6. what were the requirements of the previous AML regime? A2. Please include link to the regulator(s) website A3. Who is the regulator for AML controls for: (a) Banking.bceao.int b) None c) None Q4. Q2. please find a link to a relevant report (if publicly available). as the context requires. PwCIL does not provide any services on it. responsible All rights reserved.

the bank’s senior management may give authorisation before an account opening. You should not act upon the information contained in this publication without obtaining specific professional advice. Q13. c) public officials require a heightened scrutiny. Banks must acquire information on the compliance of their correspondent with Anti Money laundering regulation. All rights reserved. The requirements are: a) verification of the identity and address of the customer by reference to official identity papers. No representation or warranty (express or implied) is given as to the accuracy or completeness of the information contained in this publication. each of which is a separate and independent legal entity. its members. or refraining to act. To whom are Suspicious Activity Reports (SARs) made? Please include a link to their website. Are relationships with shell banks specifically prohibited? A16. What publication or for was the any decision volume based on it. the verification of legal documents and legal representatives is required. The requirements are: a) Obtain information on the beneficial owner. Q11. Customer due diligence arrangements are reduced for low value transactions. A18. Q15. What are the high level requirements for verification of customer identification information (individuals and legal entities)? A9. and does not constitute professional advice.ci This publication has been prepared for general guidance on matters of interest for the personal use of the reader. In what circumstances are reduced/simplified due diligence arrangements available? A12. b) for legal entities. In what circumstances are enhanced customer due diligence measures required? A13. b) Verification of the identification and the address of the professional intermediary. responsibility or duty of care for any consequences of you or anyone else acting. www. None in the practice. d) the bank must collect information to cover the following: anticipated account activity. What are the high level requirements around beneficial ownership (identification and verification)? A11. The transactions in their accounts require heightened scrutiny. The relationship must not be established if the correspondent is not compliant with AML regulation. What enhanced due diligence must be performed for correspondent banking relationships (cross-border banking and similar relationships)? A15. In what circumstances is additional due diligence required for non face-to-face transactions and/or relationships? A17. Q14. Q10. For a PEP. Where copies of identification documentation are provided. and. Yes. For a non face-to-face relationship. to the extent permitted by law. Customer due diligence is enhanced for unusual or suspicious activities/transactions. Reporting Q18.  2010 – 56 SARs . Copies of identification documentation are only made by the bank after a visual check. © 2009 PricewaterhouseCoopers. The application and impact of laws can vary widely based on the specific facts involved. Q12. . source of wealth and sources of funds. In what circumstances is additional due diligence required for Politically Exposed Persons (‘PEPs’)? A14. what are the requirements around independent verification or authentication? A10. Independent verification is not required. Q17. employees and agents do not accept or assume any liability. in reliance on the information contained in this Q19.centif.Questions and Answers: ‘Know Your Customer’ quick reference guide Country by country comparison of high level Know Your Customer and Anti-Money Laundering information Q9. National Centre for Processing of Financial Information (CENTIF). Volume of International SARs: Limited. Q16. PricewaterhouseCoopers LLP. a bank must consider the need to perform independent verification. of SARs made to the authorities in the most recent year? Please state the GDP for the equivalent year. “PricewaterhouseCoopers” refers to the network of member firms of PricewaterhouseCoopers A19.

(CENTIF). employees and agents do not accept or assume any liability. of SARs: A19. Yes. responsibility or duty of care for any consequences of you or anyone else acting. . tipping unusual transactions. quality refers to in assurance. to the extent permitted by law. or refraining to act. Q24. Q23. in reliance on the information contained in this publication or for any decision based on it. It is calculated without making deductions for depreciation of fabricated assets or for depletion and degradation of natural resources.pwc. tax and of member advisory firms of  services. an alternative conversion factor is used. or refraining to act.8 Financial million Information of GDP. and does not constitute professional advice.S. dollars. or refraining to act. Q25. Are there any obligations to report anything more than suspicious transactions e. There Volumeis an obligation to report on transactions where the identity of the beneficiary or the originator is suspicious. A20.com. Q20. For a few countries where the official exchange rate does not reflect the rate effectively applied to actual foreign exchange transactions.S. the network each of which is a separate and independent legal entity. A22. This publication has been prepared for general guidance on matters of interest for the personal use of the reader.g. 2010 – 56 SARs GDP Are (in current there prices): thresholds below which transactions do not need to be reported? any de-minimis Q21. its members. to the extent permitted by law. cash transactions above a certain Q22. and does not constitute professional advice. Dollar figures for GDP are converted from domestic currencies using single year official exchange rates. There is an obligation to report on transactions where the identity of the beneficiary or the originator is suspicious. each of which is a separate and independent legal entity. cash transactions above a certain threshold. to the extent permitted by law. What was the volume of SARs made to the authorities in the most recent year? Please state the GDP for the equivalent year.g. employees and agents do not accept or assume any liability. A20.? A22. Are there Are there any anypenalties obligations fortonon report anythingwith compliance more than suspicious reporting transactions requirements e. in reliance on the information contained in this publication or for any decision based on it. “PricewaterhouseCoopers” refers to the network of member firms of PricewaterhouseCoopers International Limited. Dollar figures for GDP are converted from domestic currencies using single year official exchange rates. Q25. threshold. Is there a requirement to obtain authority to proceed with a current/ongoing transaction that is identified as suspicious? Q22. No. Are there any requirements (legal or regulatory) to use automated Suspicious Transaction monitoring technology? A25. 2010 – USD22. What was the volume of SARs made to the authorities in the most recent year? Please state the GDP for the equivalent year. All rights reserved. and. Data are in current U. unusual transactions.g. responsibility or duty of care for any consequences of you or anyone else acting. PwC helps organisations and individuals create the value they’re looking for. All rights reserved. . its members.ci Country by country comparison of high level Know Your Customer and Anti-Money Laundering information Q20. Are there any penalties for non compliance with reporting requirements e. and. No. www.780 million (Source: data. You should not act upon the information contained in this publication without obtaining specific professional advice. Does the local legislation allow transactions to be monitored outside the jurisdiction? Q23. other transactions etc. * 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. Data are in current U. Volume of SARs: 2010 – 56 SARs Questions and prices): GDP (in current Answers: * ‘Know Your Customer’ quick reference guide 2010 – USD22. Is there a requirement to obtain authority to proceed with a current/ongoing transaction that is identified as suspicious? A24. . dollars. No. You should not act upon the information contained in this publication without obtaining specific professional advice.worldbank. © 2009 PricewaterhouseCoopers.? Q19. We’re a network of firms in 158 countries with more than 180. A19. No representation or warranty (express or implied) is given as to the accuracy or completeness of the information contained in this publication. The application and impact of laws can vary widely based on the specific facts involved. For a few countries where the official exchange rate does not reflect the rate effectively applied to actual foreign exchange transactions. No. Does the local legislation allow transactions to be monitored outside the jurisdiction? A25. This publication has been prepared for general guidance on matters of interest for the personal use of the reader. Tell us what matters to you and find out more by visiting us at This publication has been prepared for general guidance on matters of interest only.8 million of GDP. It is calculated without making deductions for depreciation of fabricated assets or for depletion and degradation of natural resources.org ) This results National in a ratio Centre of 1 SAR for for Processing of every USD406.centif. in reliance on the information contained in this publication or for any decision based on it. international wire transfers. The application and impact of laws can vary widely based on the specific facts involved. You should not act upon the information contained in this publication without obtaining specific professional advice. PricewaterhouseCoopers LLP. A18. and. Q24. off? e.000 people“PricewaterhouseCoopers” © 2009 PricewaterhouseCoopers.org * ) A21. Q19.worldbank. an alternative conversion factor is used. Are there any requirements (legal or regulatory) to use automated Suspicious Transaction monitoring technology? Q21. No. PwC does do not accept or assume any liability.  * 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. and does not constitute professional advice. No. PricewaterhouseCoopers LLP.780 million (Source: data. responsibility or duty of care for any consequences of you or anyone else acting. No representation or warranty (express or implied) is given as to the accuracy or completeness of the information contained in this publication. Yes. tipping off? A24. A23. No. other transactions etc. No representation or warranty (express or implied) is given as to the accuracy or completeness of the information contained in this publication. No. who are committed to delivering PricewaterhouseCoopers International Limited. A21. international wire transfers. This results in a ratio of 1 SAR for every USD406. www.g. Are there any de-minimis thresholds below which transactions do not need to be reported? A23.

). . what were the requirements of the previous AML regime? A2. what are the various thresholds in place? A8. to the extent permitted by law. and does not constitute professional advice.Box 5689 Douala. Is there any practical guidance provided to firms by public authorities regarding AML requirements. publication or forindividual member any decision basedfirms of the PwC network. The Design Group 21383 (01/13) network exercise of member of another firms firm’s member of  professional judgment or bind another member firm or PwCIL in any way.pwc. (c) Non financial sector (e.com Cameroon January 2013 Tel: +237 77 93 40 70 General Q1. Is a risk based approach approved by the local regulator(s)? A6. N/A Q3. Each member firm is a separate legal entity and does not act as agent of PwCIL or any other member firm.there are no minimum transaction thresholds under which customer due diligence is not required.O. PwCIL does not provide any services on it. Are there minimum transaction thresholds. Customer due diligence Q8. employees and ©agents 2013 PwC. Q6.Questions and Answers: ‘Know Your Customer’ quick reference guide Country by country comparison of high level Know Your Customer and Anti-Money Laundering information Cameroon Key contact: Douty Fadiga Postal address: P. “PwC” of consequences refers you to or the network anyone elseof member acting. and. (b) Other financial Services. high value goods etc. do notAll rightsor accept reserved. www. This publication has been prepared for general guidance on matters of interest for the personal use of the reader. No – there is no risk based approach approved by the local regulator. A4. assumeNot anyfor furtherresponsibility liability.g. Is there a requirement to retrospectively verify the identity of customers before the date the new AML regime was introduced? A5.int b) None c) None Q4. No member firm is © 2009 PricewaterhouseCoopers. under which customer due diligence is not required? If Yes. No . If the AML laws and/or regulations became effective in the last 2 years.fadiga@cm. casinos. A7. Yes the country has been subjected to a FATF evaluation. as the context requires. The application and impact of laws can vary widely based on the specific facts involved. Please include link to the regulator(s) website A3. firms of PricewaterhouseCoopers or refraining to act. AML law and regulations became effective in 2005 and are only applicable for banks. responsible All rights reserved. a) The Banking Commission. 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). No representation or warranty (express or implied) is given as to the accuracy or completeness of the information contained in this publication.an update of the customer database is required. Last updated: Email: d. Yes . Who is the regulator for AML controls for: (a) Banking. its members. beyond the FATF recommendations and local legislation? Please include link to website. each of which is a separate and independent legal entity. information contained in this or. In what year did the relevant AML laws and regulations become effective? A1.beac. or liable for the acts or omissions “PricewaterhouseCoopers” of any other refers the member firm nor can it control to the PricewaterhouseCoopers International Limited. Q2. but the report is not publicly available. distribution without or duty the permission of care for any of PwC. Q7. No Q5. You should not act upon the information contained in this publication without obtaining specific professional advice. PricewaterhouseCoopers LLP. 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. where available. in reliance on the International Limited (PwCIL). to clients. .

Q10. d) the bank must collect information to cover the following: anticipated account activity. The application the authorities in and theimpact mostofrecent laws can vary widely year? based Please on thethe state specific GDP facts forinvolved.394 million (Source: data. Customer due diligence arrangements are reduced for low value transactions. the verification of legal documents and legal representatives is required. Copies of identification documentation are only made by the bank after a visual check.worldbank. In what circumstances is additional due diligence required for Politically Exposed Persons (‘PEPs’)? A14. employees and agents do not accept or assume any liability. “PricewaterhouseCoopers” refers to the network of member firms of PricewaterhouseCoopers International Limited. its members. a) Obtain information on the beneficial owner. What enhanced due diligence must be performed for correspondent banking relationships (cross-border banking and similar relationships)? A15. Q12. in practice. a) verification of the identity and address of the customer by reference to official identity papers. National Agency for financial investigation (ANIF). Reporting Q18. Banks must acquire information on the compliance of their correspondent with Anti Money laundering regulation. what are the requirements around independent verification or authentication? A10. The relationship must not be established if the correspondent is not compliant with AML regulation. or refraining to act. For a PEP. Q16. What are the high level requirements around beneficial ownership (identification and verification)? A11. This publication has been prepared for general guidance on matters of interest for the personal use of the reader. Q15. or implied) is given as to the accuracy or completeness of the information contained in this publication. In what circumstances are reduced/simplified due diligence arrangements available? A12. responsibility or duty of care for any consequences of you or anyone else acting. and does not constitute professional advice. What are the high level requirements for verification of customer identification information (individuals and legal entities)? A9. No representation the equivalent year. or warranty (express Q19. c) public officials require a heightened scrutiny. each of which is a separate and independent legal entity. www. An independent verification is not required.org * ) . source of wealth and sources of funds. Q11. In what circumstances are enhanced customer due diligence measures required? A13.anif. All rights reserved.cm .  GDP (in current prices): 2010 – USD22. To whom are Suspicious Activity Reports (SARs) made? Please include a link to their website. You should not act upon the information contained in this publication What was without obtaining the volume ofspecific SARsprofessional made toadvice. Are relationships with shell banks specifically prohibited? A16. and. Customer due diligence is enhanced for unusual or suspicious activities/transactions. In what circumstances is additional due diligence required for non face-to-face transactions and/or relationships? A17. The transactions in their accounts require heightened scrutiny. Q13. to the extent permitted by law. Q14. a bank must consider the need to perform independent verification. b) Verification of the identification and the address of the professional intermediary. PricewaterhouseCoopers LLP. None.Questions and Answers: ‘Know Your Customer’ quick reference guide Country by country comparison of high level Know Your Customer and Anti-Money Laundering information Q9. A18. Volume of SARs: 2010 – 124 SARs © 2009 PricewaterhouseCoopers. A19. Yes. Q17. For a non face-to-face relationship. Where copies of identification documentation are provided. in reliance on the information contained in this publication or for any decision based on it. b) for legal entities. the bank’s senior management must give authorisation before an account opening.

No. PwC helps organisations and individuals create the value they’re looking for. Data are in current U. each of which is a separate and independent legal entity.transaction tipping off?that is identified as suspicious? A24.g. people“PricewaterhouseCoopers” PricewaterhouseCoopers International Limited. Are there What wasanytheobligations to report volume of SARs anything made to the more than suspicious authorities in the mosttransactions recent year?e. Q19. Q20. No. No representation or warranty (express or implied) is given as to the accuracy or completeness of the information contained in this publication. Q24.anif. You should not act upon the information contained in this publication without obtaining specific professional advice. PricewaterhouseCoopers LLP. Are there any penalties for non compliance with reporting requirements e. No. Are there any obligations to report anything more than suspicious transactions e. to the extent permitted by law.S. A19. responsibility or duty of care for any consequences of you or anyone else acting.cm Country by country comparison of high level Know Your Customer and Anti-Money Laundering information Q20. Q23. GDP (in current prices): 2010 – USD22. Are there any de minimis thresholds below which transactions do not need to be reported? This results in a ratio of 1 SAR for every USD180.worldbank. tipping off? A20. No representation or warranty (express or implied) is given as to the accuracy or completeness of the information contained in this publication. threshold. All rights reserved. For a few countries where the official exchange rate does not reflect the rate effectively applied to actual foreign exchange transactions. PricewaterhouseCoopers LLP. Your Customer’ quick reference guide 2010 – USD22.g. Does the local legislation allow transactions to be monitored outside the jurisdiction? A25. No. A25. No representation or warranty (express or implied) is given as to the accuracy or completeness of the information contained in this publication. All rights reserved. and. Q19. and does not constitute professional advice. No. each refers to who are committed to delivering the network quality of member in assurance. cash transactions above a certain threshold. Q25.org * ) National Agency for financial investigation (ANIF).pwc.S. or refraining to act. What was the volume of SARs made to the authorities in the most recent year? Please state the GDP for the equivalent year. to the extent permitted by law. dollars. Dollar figures for GDP are converted from domestic currencies using single year official exchange rates. It is calculated without making deductions for depreciation of fabricated assets or for depletion and degradation of natural resources. in reliance on the information contained in this publication or for any decision based on it. firms tax and of advisory  services.g. The application and impact of laws can vary widely based on the specific facts involved. Dollar figures for GDP are converted from domestic currencies using single year official exchange rates.org * ) Q21. dollars. No. “PricewaterhouseCoopers” refers to the network of member firms of PricewaterhouseCoopers International Limited. . A21. There is an obligation to report on transactions where the identity of the beneficiary or the originator is suspicious. This results in a ratio of 1 SAR for every USD180.g. employees and agents do not accept or assume any liability. employees and agents do not accept or assume any liability. Q21. Volume of SARs: 2010 –is124 There SARs an obligation to report on transactions where the identity of the beneficiary or the originator is suspicious. other transactions etc. © 2009 PricewaterhouseCoopers. or refraining to act. its members. A22. No.6 million of GDP. www.394 million (Source: data.com. You should not act upon the information contained in this publication without obtaining specific professional advice. Q23. No. and. Is there a requirement to obtain authority to proceed with a current/ongoing transaction that is identified as suspicious? A24. www. Is there Are a requirement there any penaltiestofor obtain non authority complianceto proceed with arequirements with reporting current/ongoing e.6 million of GDP. You should not act upon the information contained in this publication without obtaining specific professional advice. It is calculated without making deductions for depreciation of fabricated assets or for depletion and degradation of natural resources. A22. unusual transactions. Data are in current U. an alternative conversion factor is used. . and does not constitute professional advice. The application and impact of laws can vary widely based on the specific facts involved. and does not constitute professional advice. 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. We’re a network of firms in 158 countries with more than 180. * 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. to the extent permitted by law. international wire transfers. the GDP forcash transactions the equivalent above a certain year.000 © 2009 PricewaterhouseCoopers.worldbank. an alternative conversion factor is used. in reliance on the information contained in this publication or for any decision based on it. This publication has been prepared for general guidance on matters of interest for the personal use of the reader. A20. This publication has been prepared for general guidance on matters of interest for the personal use of the reader. Yes. . A23. PwC does do not accept or assume any liability.  * 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. Q24. For a few countries where the official exchange rate does not reflect the rate effectively applied to actual foreign exchange transactions. Volume of SARs: 2010 – 124 SARs Questions and Answers: GDP (in current prices): ‘Know A18. in reliance on the information contained in this publication or for any decision based on it. or refraining to act. responsibility or duty of care for any consequences of you or anyone else acting. its members. international wire transfers. of which is a separate and independent legal entity.394 million (Source: data.? A19.? Q22. Tell us what matters to you and find out more by visiting us at This publication has been prepared for general guidance on matters of interest only. responsibility or duty of care for any consequences of you or anyone else acting. Q22. other transactions etc. unusual Please statetransactions. A21. Are there Does any requirements the local (legal legislation allow or regulatory) transactions to betomonitored use automated outsideSuspicious Transaction monitoring technology? the jurisdiction? Q25. Yes. and.

html (June 2012).org/external/country/ago/index. to clients.htm. in reliance on the International Limited (PwCIL). responsible All rights reserved. This may be clarified in Regulation expected to be issued in the near future. provides that. (b) Other financial Services. A4.º 12/10.g. assumeNot anyfor furtherresponsibility liability. 1º andar. This publication has been prepared for general guidance on matters of interest for the personal use of the reader. where available. However.com Largo 4 de Fevereiro n. If the AML laws and/or regulations became effective in the last 2 years. FATF published a Global AML/ CFT Compliance publication where Angola’s AML regime is briefly analysed.org/external/pubs/cat/longres. No representation or warranty (express or implied) is given as to the accuracy or completeness of the information contained in this publication. and does not constitute professional advice. taking into account the risk associated with the type of customer.ao b) Direcção Nacional de Investigação e Inspecção das Actividades Económicas do Comando Geral da Policia Nacional - http://www. in February 2012 and in June 2012. In what year did the relevant AML laws and regulations become effective? A1.org/countries/a-c/angola/documents/improvingglobalamlcftcomplianceon-goingprocess-22june2012. A7. The links to these publications are http://www. casinos. what were the requirements of the previous AML regime? A2.policiaeconomica. Who is the regulator for AML controls for: (a) Banking.º3. You should not act upon the information contained in this publication without obtaining specific professional advice. Law n. “PwC” of consequences refers you to or the network anyone elseofacting. please find a link to a relevant report (if publicly available). . PricewaterhouseCoopers LLP. 2010.). its members.html (February 2012) http://www. Q5.bna. No member firm is © 2009 PricewaterhouseCoopers. employees and ©agents 2013 PwC.fatf- gafi. The last IMF Country Report was published in May 2012. publication or forindividual member any decision basedfirms of the PwC network. do notAll rightsor accept reserved. 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. the product. Angola has not been the subject of a FATF Mutual Evaluation. Each member firm is a separate legal entity and does not act as agent of PwCIL or any other member firm.org/countries/s-t/turkmenistan/documents/improvingglobalamlcftcomplianceon-goingprocess-16february2012. Angola General Q1.aspx?sk=25888. the type of transaction and the origin or the purpose of the funds.0 The country page (Angola and IMF) is http://www. Please include link to the regulator(s) website A3. in compliance with identification and diligence requirements. distribution without or duty the permission of care for any of PwC. PwCIL does not provide any services on it.luz@pt. as the context requires. to the extent permitted by law. No. Law n.imf. information contained in this or.fatf-gafi. the business relationship.gv. financial institutions can adapt the nature and scope of verification and diligence procedures.Questions and Answers: ‘Know Your Customer’ quick reference guide Country by country comparison of high level Know Your Customer and Anti-Money Laundering information Angola Key contact: Manuel Luz Postal address: Presidente Business Center Last updated: Email: manuel. and. beyond the FATF recommendations and local legislation? Please include link to website. Is there a requirement to retrospectively verify the identity of customers before the date the new AML regime was introduced? A5. Q7.º 12/10 was issued on 9/7/2010 and Aviso Nº 22/2012 Q2.Sala 137 January 2013 Tel: +351 21 359 9304 Luanda . 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. N/A Q3. Is a risk based approach approved by the local regulator(s)? A6. Law n. The Design Group 21383 (01/13) network exercise of member of another firms firm’s member of  professional judgment or bind another member firm or PwCIL in any way. or liable for the acts or omissions “PricewaterhouseCoopers” of any other refers the member firm nor can it control to the PricewaterhouseCoopers International Limited.º 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. each of which is a separate and independent legal entity. member firms of PricewaterhouseCoopers or refraining to act. Q6. Customer due diligence . (c) Non financial sector (e.www. high value goods etc. The report is the sixth country review under the stand-by agreement.ao/ Q4. Is there any practical guidance provided to firms by public authorities regarding AML requirements. The regulator for AML controls are: a) Banco Nacional de Angola .pwc. The application and impact of laws can vary widely based on the specific facts involved. The report’s link is http://www.imf.

A8. In such relationships. each of which is a separate and independent legal entity. Q13. nationality. this relationship must take into consideration the bank’s country and it’s AML risk. Q14.org/external/country/ago/index. and conduct enhanced ongoing monitoring of the business relationship. In what circumstances is additional due diligence required for Politically Exposed Persons (‘PEPs’)? A14. A7.html (June 2012). 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. relationships? LLP.0 The country page (Angola and IMF) is http://www. in February 2012 and in June 2012. with Politically Exposed Persons (‘PEPs’). Where copies of identification documentation are provided. Those measures are always required when operations are carried out with non face-to-face customers. or refraining to act. Q10. its members. Non face-to-face relationships (especially those that can favour anonymity) require additional due diligence. its members. the analysis of the bank’s internal procedures regarding the international laws of anti-money laundering. In addition. each of which is a separate and independent legal entity. regional or local level).imf. Country by country comparison of high level Know Your Customer and Anti-Money Laundering information Customer due diligence . employees and PricewaterhouseCoopers agents do not accept or assume any liability. birth date. Individuals . take adequate measures to establish the source of wealth and funds involved in the business relationship or occasional transactions. In what circumstances are enhanced customer due diligence measures required? A13. Q11. b) where the customer is a Governmental Authority or Public Institute subject to transparent accounting practices and supervision. You should not act upon the information contained in this publication without obtaining specific professional advice. What are the high level requirements around beneficial ownership (identification and verification)? A11.000 (or equivalent in local currency). The links to these publications are http://www.org/external/pubs/cat/longres. Q15. those designated by the competent supervisory authorities and Private Banking.occasional transactions under USD15. Q12. is not and does notconstitute required?professional advice. and. the financial institution should guarantee that the diligence duty was observed. in the case of correspondent banking transactions with credit institutions established in third countries. Q16. What are the high level requirements for verification of customer identification information (individuals and legal entities)? A9. to the extent permitted by law. what are the requirements around independent verification or authentication? A10. address. FATF published a Global AML/ CFT Compliance publication where Angola’s AML regime is briefly analysed.fatf- gafi.should provide a valid document with their deeds of incorporation or valid licence (certification should be made through the card Cartão de Identificação de Pessoa Colectiva or Certidão do Registo Comercial). have approval from senior management before establishing business relationships with such customers. This publicationArehasthere minimum been prepared transaction for general guidancethresholds.aspx?sk=25888.  to verify/ certify the documentation provided by the customer. responsibility or duty of care for any consequences of you or anyone else acting.org/countries/s-t/turkmenistan/documents/improvingglobalamlcftcomplianceon-goingprocess-16february2012. the guarantee of the information accuracy and the bank’s reputation. employees and agents do not accept or assume any liability. the headquarters address. The copies of documentation must be certified. Angola has not been the subject of a FATF Mutual Evaluation. “PricewaterhouseCoopers” refers to the network of member firms of PricewaterhouseCoopers International Limited. responsibility or duty of care for any consequences of you or anyone else acting. shareholder identification if more than 20% of the voting rights. profession and work place (when applicable).html (February 2012) Questions and Answers: http://www. The application and impact of laws can vary widely based on the specific facts involved. tax identification number. Yes. Corporates . No representation or warranty (express Q17. Q8. in reliance on the information contained in this publication or for any decision based on it. Are relationships with shell banks specifically prohibited? A16. 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. in reliance on the information contained in this publication or for any decision based on it.fatf-gafi. What enhanced due diligence must be performed for correspondent banking relationships (cross-border banking and similar relationships)? A15. This publication has been prepared for general guidance on matters of interest for the personal use of the reader. This may be provided by another financial institution or it can be requested that the first payment is made through an account . to the extenttransactions and/or permitted by law. When establishing a relationship with a non resident PEP. signature. the © 2009 PricewaterhouseCoopers. and. When establishing a relationship through correspondence with third country banks. what are the various thresholds in place? or implied) is given as to the accuracy or completeness of the information contained in this publication.imf. funds provenience and tax identification number (optional). Yes . All rights reserved. No representation or warranty (express If Yes.org/countries/a-c/angola/documents/improvingglobalamlcftcomplianceon-goingprocess-22june2012. a) where the customer is a State or a Public Sector Entity (at country. You should not act upon the information contained in this publication without obtaining specific professional advice. However. The report’s link is http://www. . The application and impact of laws can vary widely based on the specific facts involved. © 2009 PricewaterhouseCoopers. PricewaterhouseCoopers LLP. and board of directors identification. Management Board and shareholder identification must occur if more than 20% of the voting rights are held.  Q9. the entities should have appropriate risk based procedures to determine whether the customer is a PEP. In what circumstances are reduced/simplified due diligence arrangements available? A12. underforwhich on matters of interest customer the personal use of due diligence the reader. “PricewaterhouseCoopers” refers to the network of member firms of institution should either ask for the legal documentation as for additional documentation PricewaterhouseCoopers International Limited. All rights reserved.htm. Identification and verification requirements for beneficial owners are the same as those for individuals or companies listed above. A PEP relationship requires additional due diligence. The report is the sixth country review under the stand-by agreement. or refraining to act. a resident outside the national territory. and does not constitute professional advice. A17.should provide a valid document with: full name. ‘Know Your Customer’ quick reference guide The last IMF Country Report was published in May 2012.

Information on the volume of SARs is not publicly available. In such relationships. Non face-to-face relationships (especially those that can favour anonymity) require additional due diligence. All rights reserved.policiaeconomica.ao/ . A19. 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. the institution should either ask for the legal documentation as for additional documentation to verify/ certify the documentation provided by the customer. country comparison of high level Know Your Customer and Anti-Money Laundering information Q17.g. Are there any de-minimis thresholds below which transactions do not need to be reported? A21. Reporting Q18. Q23. responsibility PwC helps or duty of careand organisations for any consequences individuals of you create the or they’re value anyonelooking else acting. Is there a requirement to obtain authority to proceed with a current/ongoing transaction that is identified as suspicious? A24.? A20. You should not act upon the information contained in this publication without obtaining specific professional advice.pwc. Tell us what matters to you and find out more by visiting us at www. 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. Q21. PricewaterhouseCoopers International Limited. Are there any penalties for non compliance with reporting requirements e. a network in reliance of firms in 158on the information countries contained with more in this than 180. Q20. No representation or warranty (express or implied) is given as to the accuracy or completeness of the information contained in this publication. . No. tax and advisory services. . PwC does do not accept or assume any liability. other transactions etc.http://www. and does not constitute professional advice. international wire transfers. To whom are Suspicious Activity Reports (SARs) made? Please include a link to their website.000 publication or for any decision based on it. responsibility or duty of care for any consequences of you or anyone else acting. Does the local legislation allow transactions to be monitored outside the jurisdiction? A25. You should not act upon the information contained in this publication without obtaining specific professional advice. to the extent permitted by law. cash transactions above a certain threshold. Q25. © 2009 PricewaterhouseCoopers.com. or refraining to act. We’re to act.bna.ao – and Direcção Nacional de Investigação e Inspecção das Actividades Económicas do Comando Geral da Policia Nacional . What was the volume of SARs made to the authorities in the most recent year? Please state the GDP for the equivalent year. people who are committed to delivering quality in assurance.g.Questions and Answers: ‘Know Your Customer’ quick reference guide A16. in reliance on the information contained in this publication or for any decision based on it. In what circumstances is additional due diligence required for non face-to-face transactions and/or relationships? A17. its members. Q24. The application and impact of laws can vary widely based on the specific facts involved. No. No. and does not constitute professional advice. Q22. or refraining for. No. employees and agents do not accept or assume any liability. Are there any requirements (legal or regulatory) to use automated Suspicious Transaction monitoring technology? A23. This publication has been prepared for general guidance on matters of interest for the personal use of the reader.gv. Are there any obligations to report anything more than suspicious transactions e.www. unusual transactions. Q19. No. tipping off? A22. by Country Yes. No representation or warranty (express or implied) is given as to the accuracy or completeness of the information contained in this publication. on matters of interest only. and. The Suspicious Activity Reports ( SARs) are made to Banco Nacional de Angola . PricewaterhouseCoopers LLP. to the extent permitted by law. A18. and. No.

publication or forindividual member any decision basedfirms of the PwC network. and its membership in the Federal Reserve System. assumeNot anyfor furtherresponsibility liability. Commodity and Futures Firms: U. Intercept and Obstruct Terrorism Act of 2001 (USA PATRIOT Act) g) Intelligence Reform & Terrorism Prevention Act of 2004 h) Comprehensive Iran Sanctions. high value goods etc.futures.aspx b.S.pwc.ncua. The Design Group 21383 (01/13) network exercise of member of another firms firm’s member of  professional judgment or bind another member firm or PwCIL in any way. Treasury Department http://www. or liable for the acts or omissions “PricewaterhouseCoopers” of any other refers the member firm nor can it control to the PricewaterhouseCoopers International Limited. Q2. do notAll rightsor accept reserved.gov/ b. member firms of PricewaterhouseCoopers or refraining to act. . N/A Q3. This publication has been prepared for general guidance on matters of interest for the personal use of the reader. Treasury Department http://www. as the context requires.irs. In 1970 the United States Congress passed the Currency and Foreign Transactions Reporting Act.org/index. Each member firm is a separate legal entity and does not act as agent of PwCIL or any other member firm.gov/index.gov/ c) Non-Financial sector: The Internal Revenue Service (IRS) of the U. Since the passing of the BSA. Who is the regulator for AML controls for: (a) Banking. Accountability.gov/ g. a bank’s federal regulator will be one of the following: a. Securities and Exchange Commission http://www.federalreserve.org/ e.sec. its members. Federal Deposit Insurance Corporation (FDIC) http://www. Non-bank residential mortgage lenders and originators as loan or finance companies: The Internal Revenue Service (IRS) of the U. information contained in this or.g.fdic. where available. If the AML laws and/or regulations became effective in the last 2 years.com McLean.S. to the extent permitted by law. Commodities Futures Trading Commission (CFTC) http://www. Treasury Department (OCC) http://www.gov/ d. You should not act upon the information contained in this publication without obtaining specific professional advice. FinCEN relies on other US regulators to apply and examine for compliance with FinCEN’s regulations. 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.nfa.S. These other regulators are as follows: a) Banking: Depending upon the type of banking charter an institution has. in reliance on the International Limited (PwCIL).lavine@us.gov/ Q4. Treasury Department http://www. . and does not constitute professional advice. each of which is a separate and independent legal entity.S. PricewaterhouseCoopers LLP.Questions and Answers: ‘Know Your Customer’ quick reference guide Country by country comparison of high level Know Your Customer and Anti-Money Laundering information United States of America Key contact: Jeff Lavine Postal address: 1800 Tysons Boulevard Last updated: Email: jeff. distribution without or duty the permission of care for any of PwC. responsible All rights reserved. VA 22102-4261.gov/ b) Other Financial Services: a. Broker Dealers: U. (b) Other financial Services.gov/. commonly known as the Bank Secrecy Act (BSA). No member firm is © 2009 PricewaterhouseCoopers. Registered Mutual Funds: U. Money Services Businesses (MSB): The Financial Crimes Enforcement Network (FinCEN) of the U.S. employees and ©agents 2013 PwC. USA January 2013 Tel: +1 (703) 918-1379 General Q1. In what year did the relevant AML laws and regulations become effective? A1.S.gov/ and the Financial Industry Regulatory Authority (FINRA) http://www.htm and the National Futures Association (NFA) http://www.cftc.gov/Pages/default.occ. The Financial Crimes Enforcement Network (FinCEN) of the U.S. and.htm c. Board of Governors of the Federal Reserve System (Fed) http://www. The application and impact of laws can vary widely based on the specific facts involved.treas.gov/ f. Insurance Companies: The Internal Revenue Service (IRS) of the U.sec.fincen. “PwC” of consequences refers you to or the network anyone elseofacting.finra.S.irs. banks and other financial institutions. PwCIL does not provide any services on it.irs. several other laws have enhanced and amended the BSA to provide additional tools to combat money laundering.fincen. what were the requirements of the previous AML regime? A2. 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. The BSA established specific requirements for record keeping and reporting by private individuals.S. Treasury Department http://www. to clients. Treasury Department is the US regulator for AML regulations http://www. (c) Non financial sector (e. casinos.gov/ c. 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. and Divestment Act of 2010 The USA PATRIOT Act of 2001 is the most significant of the enhancements and amendments to the BSA. Credit Unions: National Credit Union Administration (NCUA) http://www. Securities and Exchange Commission (SEC) http://www. No representation or warranty (express or implied) is given as to the accuracy or completeness of the information contained in this publication. Office of the Comptroller of the Currency of the U.)? Please include link to the regulator(s) website A3.

and. its members.finra. The identity is verified by either the use of document verification (see examples below). 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.htm and http://www.gov/ Insurance Companies: The Internal Revenue Service (IRS) of the U.cftc. many financial institutions will use a combination of documentary and non- documentary methods to verify the identity.a risk based approach to AML is expected by US regulators.gov/IndustryOversight/AntiMoneyLaundering/index.S. No. Treasury Questions and Answers: f. beyond the FATF recommendations and local legislation? Please include link to website. Securities and Exchange Commission http://www. Money Services Businesses (MSB): The Financial Crimes Enforcement Network (FinCEN) of the U. 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. Yes . © 2009 PricewaterhouseCoopers. All rights reserved. No representation or warranty (express or implied) is given as to the accuracy or completeness of the information contained in this publication. to the extent permitted by law. You should not act upon the information compliance/NFA-futures-commission-merchants/anti-money-laundering.sec. Are there minimum transaction thresholds. or through the use of non-documentary methods (such as by comparing information provided by the customer to public databases/credit bureaus. A4.nfa.gov/bsa_aml_infobase/default.ffiec. what are the various thresholds in place? A8. Where copies of identification documentation are provided.irs.S. the identification should be certified by a notary public. No representation or warranty (express or implied) is given as to the accuracy or completeness of the information contained in this publication. PricewaterhouseCoopers LLP. PricewaterhouseCoopers LLP. Q9.finra.basic due diligence is required for all accounts/customers regardless of transaction amounts.irs.htm and the National Futures Association (NFA) http://www. Customer due diligence Q8.futures. to the extent permitted by law.Commodity and Futures Firms: U. and does not constitute professional advice. Is there a requirement to retrospectively verify the identity of customers before the date the new AML regime was introduced? © 2009 PricewaterhouseCoopers. However.htm . “PricewaterhouseCoopers” refers to the network of member firms of  PricewaterhouseCoopers International Limited. Banking: Federal Financial Institutions Examination Council (FFIEC): http://www.org/ e. in reliance on the information contained in this publication or for any decision based on it.S. A7.g.org/NFA- This publication has been prepared for general guidance on matters of interest for the personal use of the reader. For individuals.S.htm and http://www.htm Broker Dealers: http://www. Q6.gov/index. Treasury Department http://www.htm c. Is a risk based approach approved by the local regulator(s)? A6.irs. The requirements for document verification and authentication should be commensurate with the level of AML risk. please find a link to a relevant report (if publicly available). and using third party vendors which do comparisons) or a combination of both. A5. responsibility or duty of care for any consequences of you or anyone else acting. Department http://www. what are the requirements around independent verification or authentication? A10.S.fincen. “PricewaterhouseCoopers” refers to the network of member firms of . Q10. No.sec. generally the identity is verified before an account is opened. Regulatory Authority (FINRA) http://www.org/index.cftc. employees and agents do not accept or assume any liability.gov/ Country by country comparison of high level Know Your Customer and Anti-Money Laundering information Q4. The application and impact of laws can vary widely based on the specific facts involved. The non-documentary methods would provide independent validation of identity information provided by the customer.gov/ Non-Financial sector: The Internal Revenue Service (IRS) of the U. Q11. and.org/Industry/Issues/AML/ Registered Mutual Funds: http://www. or refraining to act. All rights reserved. At a minimum. its members. responsibility or duty of care for any consequences of you or anyone else acting. Treasury Department http://www. where available. 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. employees and agents do not accept or assume any liability. US regulations do not specify independent verification or authentication of identification. Commodity and Futures Firms: http://www.S. Treasury Department http://www. Q5. each of which is a separate and independent legal entity. however. BSA/AML US regulatory guidance is provided in the Federal Financial Institutions Examination Council (FFIEC) BSA/AML Examination Manual (April 2010).Registered Mutual Funds: U. No . in reliance on the information contained in this publication or for any decision based on it. Commodities Futures Trading Commission (CFTC) http://www. What are the high level requirements for verification of customer identification information (individuals and legal entities)? A9.HTML contained in this publication without obtaining specific professional advice.gov/ ‘Know Your Customer’ quick reference guide c) g. Is there any practical guidance provided to firms by public authorities regarding AML requirements.futures. You should not act upon the information contained in this publication without obtaining specific professional advice.gov/spotlight/moneylaundering. and as such requirements can differ based upon the account/customer type and assigned risk rating.gov/ d. or refraining to act. Q7. 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. under which customer due diligence is not required? If Yes.gov/spotlight/moneylaundering. Non-bank residential mortgage lenders and originators as loan or finance companies: The Internal Revenue Service (IRS) of the U.sec. The application and impact of laws can vary widely based on the specific facts involved.nfa. the original government issued photo identification should be seen and when not possible. What are the high level requirements around beneficial ownership (identification and verification)? .

non-public business entities. 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. from. each of which is a separate and independent legal entity. No representation or warranty (express customer/account or implied) is given as to the accuracy orincreases. many financial institutions will use a combination of documentary and non- documentary methods to verify the identity. 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. No representation or warranty (express or implied) is given as to the accuracy or completeness of the information contained in this publication. 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. High risk customer relationships are generally reviewed annually. In addition. c) a business entity whose bearer shares are not under bank or trusted third party control. profile of the customer. its members. . or refraining to act. Are relationships with shell banks specifically prohibited? A16. in order to identify and report any suspicious transactions as required by US regulations and law. Enhanced scrutiny of the transactions associated with any correspondent accounts should be performed to guard against the increased risk of money laundering. What are the high level requirements around beneficial ownership (identification and verification)? A11. customers and entities that pose higher risks and enhanced due diligence for high risk customers. and. The level of ownership in a customer entity that triggers beneficial owner identification and due diligence should be determined by the AML risk . The Questions requirements for document verification and authentication should be commensurate with the level of AML risk. Factors that would be considered in determining a customer's risk rating would include at a minimum: geography. or refraining to act. b) monitoring transactions to. Q14. employees and agents do not accept or assume any liability. and. and the nature and extent of the ownership interest of each owner should be determined. Yes. individual’s position or authority. such as: a) account activity that is substantially cash-intensive. particularly foreign private banking and correspondent services. What enhanced due diligence must be performed for correspondent banking relationships (cross-border banking and similar relationships)? A15. US regulations do not specify independent ‘Know Your Customer’ quick reference guide verification or authentication of identification. You should not act upon the information contained in this publication without obtaining specific professional advice. Q10. PricewaterhouseCoopers LLP. The level of enhanced scrutiny of any account should be supported by the institution’s annual AML risk assessment and the customer's risk rating. customers classified as high risk according to the institution's customer risk rating methodology would be subject to enhanced due diligence. in reliance on the information contained in this publication or for any decision based on it. or f) private investment companies or trust accounts. For individuals. and does not constitute professional advice. its members. b) an entity whose account activity consists primarily of questionable funds transfers. nature of business/employment. 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. 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. beneficial owners. Q16. Enhanced due diligence should be performed for the owners of any foreign bank whose shares are not publically traded. the KYC and identification requirements must be followed. The identity of each of the owners of the foreign bank. All rights reserved. In addition to the normal due diligence requirements. “PricewaterhouseCoopers” refers to the network of member firms of PricewaterhouseCoopers International Limited. Q15. © 2009 PricewaterhouseCoopers. responsibility or duty of care for any consequences of you or anyone else acting. © 2009 PricewaterhouseCoopers.  Q12. the original government issued photo identification should be seen and when not possible. 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. The application and impact of laws can vary widely based on the specific facts involved. PricewaterhouseCoopers LLP.on matters of interest for the The percentage of personal use ofthat ownership the reader. completeness of the information contained in this publication. or through the correspondent account in a manner reasonably designed to detect money laundering and suspicious activity. and as such andcanAnswers: requirements differ based upon the account/customer type and assigned risk rating. to the extent permitted by law. Risk factors that may require additional due diligence for PEPs include geographic location. Where copies of identification documentation are provided. All rights reserved. products and services used. In what circumstances is additional due diligence required for Politically Exposed Persons (‘PEPs’)? A14. the identification Country by countryshould be certified comparison of by a notary high levelpublic. and due triggers does not constituteshould diligence professional be advice.  . 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. e) an entity owned or controlled by off-shore. The application and impact of laws can vary widely based on the specific facts involved. responsibility or duty of care for any consequences of you or anyone else acting. However. Local guidance also has information on products. 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. 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. The non-documentary methods would provide independent validation of identity information provided by the customer. “PricewaterhouseCoopers” refers to the network of member firms of PricewaterhouseCoopers International Limited. services. employees and agents do not accept or assume any liability. In what circumstances are reduced/simplified due diligence arrangements available? A12. especially to/from high-risk jurisdictions. what are the requirements around independent verification or authentication? A10. each of which is a separate and independent legal entity. This publication has been prepared for general guidance on matters of interest for the personal use of the reader. to the extent permitted by law. d) an entity that uses a wide range of bank services. in reliance on the information contained in this publication or for Foranyidentified decision based on it. lower You should as the AMLnot act upon risk of the theinformation contained in this publication without obtaining specific professional advice. products and services used. Know Your Customer and Anti-Money Laundering information Q11. Q13. and complexity of the account relationships. The USA PATRIOT Act requires financial institutions to increase their due diligence standards when dealing with foreign private banking and correspondent accounts. In what circumstances are enhanced customer due diligence measures required? A13.

its members. and. each of which is a separate and independent legal entity. The application and impact of laws can vary widely based on the specific facts involved. as well as in the regulations of Financial Crimes Enforcement Network (FinCEN) at http://www. Q22.fincen.gov/.000.0 trillion (Source: data. or refraining to act. unusual transactions. PricewaterhouseCoopers LLP. This publication has been prepared for general guidance on matters of interest for the personal use of the reader.fincen.5 million SARs http://www. Dollar figures for GDP are converted from domestic currencies using single year official exchange rates.000 or less c) CMIRs transactions aggregating USD10.Questions and Answers: ‘Know Your Customer’ quick reference guide Country by country comparison of high level Know Your Customer and Anti-Money Laundering information Q17. and d) Transmittal orders for funds transfers (the Travel Rule) Q21. at http://www. A19. b) requiring identification documentation to be notarised.94 million of GDP. and c) comparing the identifying information against fraud and negative check databases. It is calculated without making deductions for depreciation of fabricated assets or for depletion and degradation of natural resources.fincen.g. © 2009 PricewaterhouseCoopers. Yes.000 or less d) FBARs when the aggregate value of the foreign financial accounts are USD10. dollars. The Financial Crimes Enforcement Network (FinCEN) of the U. tipping off? A22. Q20. cash transactions above a certain threshold. etc. You should not act upon the information contained in this publication without obtaining specific professional advice.S.fincen.worldbank.gov/news_room/rp/files/btn17/sar_by_numb_17. Local guidance includes examples of non-documentary verification methods that a financial institution may use. employees and agents do not accept or assume any liability.? A20.html#SAR Q19. To whom are Suspicious Activity Reports (SARs) made? Please include a link to their website. .  .S. including: a) contacting a customer after the account is opened.g. international wire transfers.org*) This results in a ratio of 1 SAR for every USD9. 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). other transactions etc. * 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. No representation or warranty (express or implied) is given as to the accuracy or completeness of the information contained in this publication. Penalties for non-compliance are noted in the Bank Secrecy Act. What was the volume of SARs made to the authorities in the most recent year? Please state the GDP for the equivalent year. Financial institutions should take account of money laundering risks inherent to non face-to-face customer relationships.000 or less during the calendar year e) Transmittal orders for funds transfers (the Travel Rule) below USD3. to the extent permitted by law. Are there any penalties for non compliance with reporting requirements e. Volume of SARs: 2011 – 1. Yes. and does not constitute professional advice. an alternative conversion factor is used. as amended. For a few countries where the official exchange rate does not reflect the rate effectively applied to actual foreign exchange transactions.gov/forms/bsa_forms/index. Reporting Q18. in reliance on the information contained in this publication or for any decision based on it.gov/statutes_regs/bsa/. All rights reserved. A18.000 b) CTRs transactions aggregating USD10. Are there any de-minimis thresholds below which transactions do not need to be reported? A21. the institution should deploy additional monitoring controls against transactions originating in these higher risk accounts. Are there any obligations to report anything more than suspicious transactions e.pdf GDP (in current prices): 2011 – USD15. Yes. responsibility or duty of care for any consequences of you or anyone else acting. Data are in current U. “PricewaterhouseCoopers” refers to the network of member firms of PricewaterhouseCoopers International Limited. In what circumstances is additional due diligence required for non face-to-face transactions and/or relationships? A17. Where a customer approaches an institution remotely. depending upon the type of transaction for various reporting: a) SARs transactions aggregating below USD5. Treasury Department: http://www.

other transactions etc. Yes.fincen.000. PwC does do not accept or assume PricewaterhouseCoopers International Limited. A25. Are there any obligations to report anything more than suspicious transactions e. While there are no legal or regulatory requirements to use an automated system. A21. employees and agents do not accept or assume any liability.S. cash transactions above a certain threshold. For a few countries where the official exchange rate does not reflect the rate effectively applied to actual foreign exchange transactions.000 that isoridentified less during the calendar year Q24. high level Knowand Your Customer and Anti-Money Laundering information d) Transmittal orders for funds transfers (the Travel Rule) Q23. It is calculated without making deductions for depreciation of fabricated assets or for depletion and degradation of natural resources. A22. in reliance on the information contained . or refraining advice. legal of firms you or  ofanyone else acting. © 2009 PricewaterhouseCoopers. its members. not act employees upon and agents do not accept or assume any liability.000 or less c) CMIRs transactions aggregating USD10. Data are in current U.? Questions and Answers: ‘Know A20. at http://www.000 or less d) a FBARs whento the aggregate value of the foreign with afinancial accountstransaction are USD10. tax and advisory services. © 2009 PricewaterhouseCoopers. responsibility or duty of care for any consequences of you or anyone else acting. Q22. The application and impact of laws can vary widely based on the specific facts involved. people who are committed to delivering quality in assurance. an alternative conversion factor is used. Are there any penalties for non compliance with reporting requirements e. customers. each of which is a separate and independent legal entity. PricewaterhouseCoopers LLP. The application and impact of laws can vary widely based on the specific facts involved.000 reporting: b) CTRs transactions aggregating USD10. Tell us what matters to you and find out more by visiting us at This publication has been prepared for general guidance on matters of interest for the personal use of the reader. its You should members.gov/statutes_regs/bsa/. to the accuracy or completeness of the information contained in this publication.byand permitted law. contained in this publication without obtaining specific professional advice.toNo act.fincen. No.pwc. Is there requirement obtain authority to proceed current/ongoing e) Transmittal orders for funds transfers (the Travel Rule) below USD3.com. but the financial institution should determine which transactions can be monitored outside its jurisdiction on a risk adjusted basis. unusual transactions. and. Are there any de-minimis thresholds below which transactions do not need to be reported? A23. responsibility or duty of “PricewaterhouseCoopers” thisofpublication each which is a or for any and separate decision caretofor refers based on independent any the consequences network of member it. tipping off? Q25. as amended. upon the type transaction for various a) SARs transactions aggregating below USD5. and does not constitute professional advice. in any liability. “PricewaterhouseCoopers” refers to the network of member firms of PricewaterhouseCoopers International Limited. to the extent permitted by law. No representation or warranty (express or implied) is given as to the accuracy or completeness of the information contained in this publication. Dollar figures for GDP are converted from domestic currencies using single year official exchange rates. You should not act upon the information www. with particular emphasis on the composition of higher-risk products. No. in reliance onorthe representation information warranty contained (express in thisis given as or implied) publication or for any decision based on it. Penalties for non-compliance are noted in the Bank Secrecy Act. You should not act upon the information contained in this publication without obtaining specific professional advice. as suspicious? A24. Q20.g. the sophistication of monitoring systems should be dictated by the institution’s riskofprofile. Yes. This publication has been prepared for general guidance on matters of interest for the personal use of the reader. entities. responsibility or duty the information of care for contained anypublication in this consequences of you without or anyone obtaining else professional specific acting. services. . to the extent permitted by law. All rights reserved. We’re a network of firms in 158 countries with more than 180. * 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. on to and. dollars.  PwC helps organisations and individuals create the value they’re looking for. or refraining to act. LLP. entity. matters of interest the extent only. international wire transfers.g. Does the local legislation allow transactions to be monitored outside the jurisdiction? Yes. in reliance on the information contained in this publication or for any decision based on it. 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). All rights reserved.000 . as well as in the regulations of Financial Crimes Enforcement Network (FinCEN) at http://www. or refraining to act. and. and does not constitute professional advice. Are there any requirements (legal or regulatory) to use automated Suspicious Transaction monitoring technology? Q21. depending and geographies. Your Customer’ quick reference guide Yes.gov/. No representation or warranty (express This publication or implied) is given as to the accuracy or completeness has been contained of the information prepared for general in this guidance publication.does not constitute professional PricewaterhouseCoopers advice.

com / Address: Cerrito 461. Yes .gub.uy/ Q4. Who is the regulator for AML controls for: (a) Banking.835 – system controls and prevention of money laundering and financing of terrorism 1998 . PricewaterhouseCoopers LLP.a.) 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.).pwc. You should not act upon the information contained in this publication without obtaining specific professional advice.bcu. casinos. 2004 . and does not constitute professional advice. 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. especially in the case of ‘high risk’ customers. 17. each of which is a separate and independent legal entity.835. No member firm is © 2009 PricewaterhouseCoopers. Uruguayan Central Bank .correa@uy. The Design Group 21383 (01/13) network exercise of member of another firms of member  firm’s professional judgment or bind another member firm or PwCIL in any way.494 – introduced several modifications to Law 17.I. please find a link to a relevant report (if publicly available). distribution without or duty the permission of care for any of PwC. 17. Each member firm is a separate legal entity and does not act as agent of PwCIL or any other member firm. Please include link to the regulator(s) website A3. Although the published guidelines are not exhaustive. In what year did the relevant AML laws and regulations become effective? A1.016 – standards with regard to the misuse of public power (corruption) Previously.A. Is a risk based approach approved by the local regulator(s)? A6. employees and ©agents 2013 PwC.Questions and Answers: ‘Know Your Customer’ quick reference guide Country by country comparison of high level Know Your Customer and Anti-Money Laundering information Uruguay Key contact: Dannys Correa / Gabriel Rodríguez Postal address: 11000 Last updated: Email: dannys. supervisor of the financial system. where available. This publication has been prepared for general guidance on matters of interest for the personal use of the reader.F.ain. Q7.http://www. January 2013 gabriel. .Law No. publication or forindividual member any decision basedfirms of the PwC network. information contained in this or. its members. 18. Is there a requirement to retrospectively verify the identity of customers before the date the new AML regime was introduced? A5. size and complexity of their transactions.the UCB has established that the supervision process must be proactive and integrity orientated. member firms of PricewaterhouseCoopers or refraining to act. beyond the FATF recommendations and local legislation? Please include link to website. 1377 / 1373 General Q1. Uruguayan AML Laws focused on the illicit traffic of narcotic drugs but have been gradually extended to other crimes Q2.uy/ Internal Audit of the Nation .http://www.pwc. . do notAll rightsor accept reserved. No representation or warranty (express or implied) is given as to the accuracy or completeness of the information contained in this publication. Yes . high value goods etc. Q3. If the AML laws and/or regulations became effective in the last 2 years. Uruguay Tel: +598 29160463 ext. assumeNot anyfor furtherresponsibility liability.gub.the Uruguayan Central Bank (‘UCB’). 2nd Floor. An AML framework is specifically required.uy/ Q5. N/A. The application and impact of laws can vary widely based on the specific facts involved. responsible All rights reserved. 2009 .g. “PwC” of consequences refers you toor the network anyone elseofacting.gub.bcu.the Unit of Financial Information and Analysis (U. Yes . Uruguayan Central Bank (UCB) . Is there any practical guidance provided to firms by public authorities regarding AML requirements. (b) Other financial Services.Law No. they constitute a collection of types or patterns of transactions that could be linked to money laundering operations from criminal activities or terrorist financing. to clients.com Montevideo. PwCIL does not provide any services on it. to the extent permitted by law. 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. what were the requirements of the previous AML regime? A2. as the context requires. or liable for the acts or omissions “PricewaterhouseCoopers” of any other refers the member firm nor can it control to the PricewaterhouseCoopers International Limited. 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.http://www. and. Q6.Law No. focused on risks and performed on a consolidated basis.rodriguez@uy. established the requirement to periodically update information on existing clients. A4. in reliance on the International Limited (PwCIL). (c) Non financial sector (e.

representatives and those authorised to operate on behalf of individual clients. Yes . etc. The application and impact of laws can vary widely based on the specific facts involved. © 2009 PricewaterhouseCoopers. or refraining to act. d) marital status. its members. each of which under is a separate which customer and independent due diligence is legal entity. Q6. g) volume of income (on financial statements). especially in the case of ‘high risk’ customers. according to the Uruguayan Central Bank Report 2010. No representation or warranty (express or implied) is given as to the accuracy or completeness of the information contained in this publication.customer due diligence is not required on transactions below USD3. Participation in GAFISUD (Grupo de Acción Financiera de Sudamérica). size and complexity of their transactions. and. and. In what circumstances are reduced/simplified due diligence arrangements available? .the UCB has established that the supervision process must be proactive and integrity orientated. b) date and place of birth. focused on risks and performed on a consolidated basis. c) identification document. This publication has been prepared for general guidance on matters of interest for the personal use of the reader. For individuals these requirements are: a) name and surname. transaction thresholds. f) main activity. You should not act upon the information contained in this publication without obtaining specific professional advice. “PricewaterhouseCoopers” refers to the network of member firms of Q8. to the extent permitted by law. 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. Where copies of identification documentation are provided. Q12. Q11. “PricewaterhouseCoopers” refers to the network of member firms of . in reliance on the information contained in this publication or for any decision based on it. An AML framework is Country by countryrequired. Each institution also has its own policies and procedures to verify the documents and its copies. The institutions must identify their customers in compliance with the UCB requirements when they open accounts or when they process transactions. Is a risk based approach approved by the local regulator(s)? Questions and Answers: ‘Know A6. What are the high level requirements for verification of customer identification information (individuals and legal entities)? A9. b) established date. It should be ascertained whether the information on level of incomes of these customers constitutes the source of income of the account. and h) shareholders and ultimate beneficial owners. A5. Financial institutions must implement procedures in order to identify the ultimate beneficial owner of each transaction. All rights reserved. The UCB regulations establish the minimum identification requirements for individuals and legal entities. to the extent permitted by law. specifically comparison of high level Know Your Customer and Anti-Money Laundering information Q7. What are the high level requirements around beneficial ownership (identification and verification)? A11. employees and agents do not accept or assume any liability. e) bylaws and other information on the entity as registry number. Notary certification and signature verification are required to certify the validity of the documents provided. f) main activity or occupation. and g) volume of income (salary and other earnings). The above mentioned data required for individuals must be obtained for those listed as corporate managers and representatives. verify their identity and register their names as well. The same information should be obtained on all owners. . You should not act upon the information contained in this publication without obtaining specific professional advice. c) address and telephone number d) tax identification number. In the latter case. It should be ascertained whether the information on level of incomes of these customers constitutes the source of income of the account. Q9. responsibility or duty of care for any consequences of you or anyone else acting.000. on existing clients. or refraining to act. the ultimate beneficiary should be identified. PricewaterhouseCoopers LLP. e) address and telephone number. No representation or warranty (express or implied) is given as to the accuracy or completeness of the information contained in this publication.. 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. not required?  If Yes. For legal entities these requirements are: a) company name. It should be ascertained whether the customer is acting on their own or on behalf of a third party. The application and impact of laws can vary widely based on the specific facts involved. employees and Customer due diligence agents do not accept or assume any liability. All rights reserved. its members. © 2009 PricewaterhouseCoopers. what are the requirements around independent verification or authentication? A10. what are the various thresholds in place? A8. and does not constitute professional advice. in reliance on the information contained in this publication or for any decision based on it. agents. agents and those authorised to act on the company’s behalf. Your Customer’ quick reference guide Yes .000 with occasional customers. Q10. with the exception of transactions with occasional customers below USD3. responsibility or duty of care for any consequences of you or anyone else acting. A7. and does not constitute professional advice. This publication has been prepared for general guidance on matters of interest for the personal use of the reader. PricewaterhouseCoopers LLP. please find a link to a relevant report (if publicly available). Are thereInternational PricewaterhouseCoopers minimumLimited.

or refraining to act. responsibility or duty of care for any consequences of you or anyone else acting. All rights reserved.gub. their relatives and their associates. employees and agents do not accept or assume any liability.I. and does not constitute professional advice. Country by country comparison of high level Know Your Customer and Anti-Money Laundering information Q12..worldbank. Financial institutions should: a) rely on procedures that allow them to determine whether a client is a PEP. c) take reasonable measures in order to determine the origin of the funds. Reports are made to the U. Q14. The application and impact of laws can vary widely based on the specific facts involved. and does not constitute professional advice. You should not act upon the information 2011 contained in this – USD46. Your Customer’ quick reference guide Financial institutions must implement procedures in order to identify the ultimate beneficial owner of each transaction. “PricewaterhouseCoopers” refers to the network of member firms of PricewaterhouseCoopers International Limited. d) principal activities and location of the premises. Reporting Q18. Institutions of member firms of  legal entity. A13. to the extent permitted by law. evaluate and register additional information about the financial situation. b) management details. The application )and impact of laws can vary widely based on the specific facts involved. and. each of which is a separate and independent legal entity. In what circumstances is additional due diligence required for Politically Exposed Persons (‘PEPs’)? A14. in reliance on the information contained in this million of GDP. Yes . g) political context. must obtain. In what circumstances are reduced/simplified due diligence arrangements available? A12. c) reputation. Are relationships with shell banks specifically prohibited? A16. Institutions must analyse each customer and classify © 2009 PricewaterhouseCoopers. ‘Know A11.uy/ Q19. Reduced/simplified due diligence arrangements are available to 'occasional customers'. © 2009 PricewaterhouseCoopers. What was the volume of SARs made to the authorities in the most recent year? Please state the GDP for the equivalent year.http://www. A18.it is not permitted to perform any type of business with financial institutions established in jurisdictions that do not require physical presence. Questions and Answers: What are the high level requirements around beneficial ownership (identification and verification)? Q11. f) regulation and supervision in their country.  . a ratio ofresponsibility 1 SAR fororeveryduty of USD232.F. This publication has been prepared for general guidance on matters of interest for the personal use of the reader. or refraining to act.000 on an annual basis. No representation or warranty (express Q13.bcu. publication or for any decision based on it. GDP (in current prices): This publication has been prepared for general guidance on matters of interest for the personal use of the reader. A10. e) account purpose. to the extent permitted by law. which was established by Resolution of the Board of Uruguayan Central Bank Uruguayan Central Bank . their activity. Volume of SARs: 2011 – 201 SARs (Uruguayan Central Bank) . PricewaterhouseCoopers LLP. its members. and d) carry out a special and permanent assessment of the customer’s transactions. To whom are Suspicious Activity Reports (SARs) made? Please include a link to their website. and h) procedures applied in order to prevent being used for laundering of assets or financing of terrorism. Q17. 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. in order to justify the customer’s transactions and the origin of funds for those customers classified as ‘high risk’ and those with transactions over a certain limit. . What enhanced due diligence must be performed for correspondent banking relationships (cross-border banking and similar relationships)? A15.A. Financial institutions should apply additional due diligence procedures in the case of PEPs. PricewaterhouseCoopers LLP. No representation or warranty (express or implied) is given as to the accuracy or completeness of the information contained in this publication. 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. local institutions must obtain the following information in relation to foreign institutions: a) the nature of their business. Notary certification and signature verification are required to certify the validity of the documents provided. In what circumstances is additional due diligence required for non face-to-face transactions and/or relationships? A17. You should not act upon the information contained in this publication without obtaining specific professional advice. verify their identity and register their names as well.710 publication million without obtaining (Source: specific data. to Limited. required? and.org* professional advice. b) get senior management approval upon establishing a new relationship with this type of client. in reliance on the information contained in this publication or for any decision based on it. A19.4 care for any consequences of you or anyone else acting. 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. Q16. them according PricewaterhouseCoopers All rights International reserved. For correspondent banking relationships. Enhanced customer due diligence measures are required fornetwork ‘permanent customers’. “PricewaterhouseCoopers” residence each of which andand is a separate refers to the riskindependent profile. It is also not permitted to establish a relationship with foreign institutions which allow shell banks to open accounts. its members. Each institution also has its own policies and procedures to verify the documents and its copies. Q15. employees and agents do not accept or assume This results inany liability.

A19. bank deposits. in reliance on the information contained in this publication or for any decision based on it. international wire transfers. currency conversion. © 2009 PricewaterhouseCoopers. Are there any obligations to report anything more than suspicious transactions e. Q21. and. employees and agents do not accept or assume any liability.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. By the above mentioned Circular No. cash transactions above a certain threshold.000 or its equivalent in other currencies.000 or its equivalent in other currencies. foreign cheques. responsibility or duty of care for any consequences of you or anyone else acting.g. tax and advisory services. an alternative conversion factor is used. The application and impact of laws can vary widely based on the specific facts involved. You should not act upon the information contained in this publication without obtaining specific professional advice. with no apparent economic or legal justification. PwC does do not accept or assume any liability. where the counterpart is made in cash. Tell us what matters to you and find out more by visiting us at www. For a few countries where the official exchange rate does not reflect the rate effectively applied to actual foreign exchange transactions.Fines and penalties from Uruguayan Central Bank and National Internal Audit Office. Q22. shares or other securities which are easy to redeem. 1722 of UCB dated 12/21/2000.  PwC helps organisations and individuals create the value they’re looking for.pwc. No. tipping off? A22.S.g. dollars. are unusual. In addition. Q23. We’re a network of firms in 158 countries with more than 180. precious metals. You should not act upon the information contained in this publication without obtaining specific professional advice. responsibility or duty of care for any consequences of you or anyone else acting. c) purchase or sale. transactions considered suspicious can be conducted on a periodic basis or isolated and that according to the customs of the activity concerned. .worldbank. Is there a requirement to obtain authority to proceed with a current/ongoing transaction that is identified as suspicious? A24. Data are in current U.? A20. It is calculated without making deductions for depreciation of fabricated assets or for depletion and degradation of natural resources. Yes . and does not constitute professional advice.000 people who are committed to delivering quality in assurance. No representation or warranty (express or implied) is given as to the accuracy or completeness of the information contained in this publication. This publication has been prepared for general guidance on matters of interest for the personal use of the reader. Yes. or refraining to act.710 million (Source: data. or of unusual or unjustified complexity. . Q24. “PricewaterhouseCoopers” refers to the network of member firms of PricewaterhouseCoopers International Limited. See Q20 above. After a present time. to the extent permitted by law. 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. and does not constitute professional advice. for amounts in excess of USD10. Does the local legislation allow transactions to be monitored outside the jurisdiction? A25. No representation or warranty (express or implied) is given as to the accuracy or completeness of the information contained in this publication. Q25. each of which is a separate and independent legal entity. regardless of the mode of operation used for execution. its members. PricewaterhouseCoopers LLP. or refraining to act.I. unusual transactions. and.org* ) This results in a ratio of 1 SAR for every USD232. This publication has been prepared for general guidance on matters of interest only. 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. the institution should consider if it is appropriate to proceed with the transaction with the customer. Country by country comparison of high level Know Your Customer and Anti-Money Laundering information Q20. Volume of SARs: 2011 – 201 SARs (Uruguayan Central Bank) Questions and Answers: ‘Know Your Customer’ quick reference guide GDP (in current prices): 2011 – USD46. other transactions etc. Are there any penalties for non compliance with reporting requirements e.F regarding transactions covered by this where there is evidence or suspicion of involvement in the legitimisation of assets derived from criminal activities. if there is no a response from Uruguayan Central Bank regarding the reported transaction.A. Are there any requirements (legal or regulatory) to use automated Suspicious Transaction monitoring technology? A23. exchange or arbitration of foreign currency or precious metals for an amount over USD10.com. Dollar figures for GDP are converted from domestic currencies using single year official exchange rates. to the extent permitted by law. Are there any de-minimis thresholds below which transactions do not need to be reported? A21.4 million of GDP. Subjects required to report must immediately inform the U. in reliance on the information contained in this publication or for any decision based on it. All rights reserved. * 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.

Is there a requirement to retrospectively verify the identity of customers before the date the new AML regime was introduced? A5. or liable for the acts or omissions “PricewaterhouseCoopers” of any other refers the member firm nor can it control to the PricewaterhouseCoopers International Limited. information contained in this or. each of which is a separate and independent legal entity. Law against Money Laundering. its members. publication or forindividual member any decision basedfirms of the PwC network. responsible All rights reserved. Each member firm is a separate legal entity and does not act as agent of PwCIL or any other member firm.). “PwC”of consequences refers you to or the network anyone elseof member acting. the following regulations became effective: a) The Law 27765.aspx?ARE=0&PFL=2&JER=464 Q5. . 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. abduction or human trafficking. Who is the regulator for AML controls for: (a) Banking. Q6. This publication has been prepared for general guidance on matters of interest for the personal use of the reader. Anti Money Laundering Criminal Law. The requirement is to verify the identity of customers who are regulated on Supreme Decree 018-2006-JUS.pwc. in which the Notary Public must report any suspicious or unusual operation to the UIF-Peru. January 2013 guillermo. You should not act upon the information contained in this publication without obtaining specific professional advice. In what year did the relevant AML laws and regulations become effective? A1. distribution without or duty the permission of care for any of PwC. this law was modified by Law 28009 and 28306. such as SBS Resolution 5709-2012.g. Is there any practical guidance provided to firms by public authorities regarding AML requirements. terrorism. Piso 8 . 2029 / +(511) 211 6500 Ext. please find a link to a relevant report (if publicly available). Under the legal framework mentioned in A.com / Av.yong@pe. Perú Tel: +(511) 211 6500 Ext. In the current AML regime. The application and impact of laws can vary widely based on the specific facts involved. as the context requires. Q3. high value goods etc. Q4. c) The Supreme Decree 163-2002-EF. and. employees and © 2013 PwC. Note that on April 2012. agents do notAll rightsor accept reserved. and does not constitute professional advice. A3. where available. Is a risk based approach approved by the local regulator(s)? A6. 8051 General Q1. No member firm is © 2009 PricewaterhouseCoopers. Please include link to the regulator(s) website. in 2002. Illegal Mining and Organized Crime. casinos. by Legislative Decree 736 on 1991.gob. Then. The AML was included in the Peruvian Criminal Code. This law is not in force since April 2012. b) The Law 27693.sbs. 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. which was modified by Supreme Decree 018-2006-JUS in 2006. beyond the FATF recommendations and local legislation? Please include link to website. its acronym in Spanish is “UIF-Peru”). A4. No representation or warranty (express or implied) is given as to the accuracy or completeness of the information contained in this publication. to clients. what were the requirements of the previous AML regime? A2. illegal mining is also considered as an aggravation. PricewaterhouseCoopers LLP. which has replaced the Law 27765 and its modifications. (c) Non financial sector (e.pwc. Santo Toribio 143. The Design Group 21383 (01/13) network exercise of member of another firms of member  firm’s professional judgment or bind another member firm or PwCIL in any way. However. has entered in force the Legislative Decree 1106. SBS Training: http://www. The previous AML regime only considered a Money Laundering Crime where the money is obtained by drug trafficking. in reliance on the International Limited (PwCIL). The Legislative Decree 1106 includes additional control mechanisms related to criminal law. PwCIL does not provide any services on it. which replaced the AML regulation on Peruvian Criminal Law. Banking. article 293 B.com Lima 27. (b) Other financial Services. which was not modified. 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.zapata@pe.. assumeNot anyfor furtherresponsibility liability. If the AML laws and/or regulations became effective in the last 2 years. Law that creates the Peruvian Financial Intelligence Unit (AML supervisor. firms of PricewaterhouseCoopers or refraining to act. to the extent permitted by law.1. Q2. Rules of the UIF-Peru.Questions and Answers: ‘Know Your Customer’ quick reference guide Country by country comparison of high level Know Your Customer and Anti-Money Laundering information Peru Key contact: Nancy Yong / Guillermo Zapata Postal address: Last updated: Email: nancy. the local regulator may issue additional regulations in order to control AML/CFT practices.pe/0/modulos/JER/JER_Interna.

Is a risk based approach approved by the local regulator(s)? A6. of highin level which Know the Notary YourPublic must report Customer andanyAnti-Money suspicious or unusual operation Laundering to the UIF-Peru. Where copies of identification documentation are provided.000 (or its equivalent in PEN) or any other higher amount. deposit or withdraw certificates. purpose. © 2009 PricewaterhouseCoopers. bingos. the local regulator may issue additional regulations in order to control AML/CFT practices. the supervised entity must report any transaction which amounts to USD10. No representation or warranty (express or implied) is given as to the accuracy or completeness of the information contained in this publication. cashier’s check among others). Are there minimum transaction thresholds. There are the same high level requirements mentioned in A10. casinos. In order to apply for the reduced/simplified due diligence arrangements.1. among others. lottery companies. employees and agents do not accept or assume any liability. “PricewaterhouseCoopers” refers to the network of member firms of . b) report in which is defined the commercial and operative design of the product. lottery companies. documents used in funds transfer. each of which is a separate and independent legal entity. casinos. under which customer due diligence is not required? If Yes. A7. employees and agents do not accept or assume any liability. birth date. please find a link to a relevant report (if publicly available). including distribution channels. and does not constitute professional advice. profession or occupation and domicile).fatf-gafi. Last Mutual Report FATF/GAFI was executed on July 2005): http://www. Q11. in reliance on the information contained in this publication or for any decision based on it. such Country by as SBS Resolution country comparison 5709-2012. place of the operation and other supporting documentation (bank statements. In what circumstances are enhanced customer due diligence measures required? . b) Aspects in order to consider the operation as suspicious. What are the high level requirements for verification of customer identification information (individuals and legal entities)? A9. among other special mechanisms. According to Supreme Decree 018-2006-JUS. “PricewaterhouseCoopers” refers to the network of member firms of PricewaterhouseCoopers International Limited. Q10. c) Other relevant information or documentation. and does not constitute professional advice. © 2009 PricewaterhouseCoopers. The supervised entity must report to the UIF-Peru the following: a) Description of the operations executed. credit/debit notes. Under the legal framework mentioned in A. what are the requirements around independent verification or authentication? A10. responsibility or duty of care for any consequences of you or anyone else acting. Individuals: Complete surname and name. which amounts to USD50. The application and impact of laws can vary widely based on the specific facts involved. You should not act upon the information contained in this publication without obtaining specific professional advice. identification document. identification document.1. in reliance on the information contained in this Customer due diligence publication or for any decision based on it. or refraining to act. taxpayer registration number. This publication has been prepared for general guidance on matters of interest for the personal use of the reader. bingos. Q9. Legal entities: name. birth date. to the extent permitted by law. the supervised entity must apply for an authorization from the SBS. 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. All rights reserved. article 9. c) risk Management Program applicable to the product.  Q8. services and distribution channels mitigate the risks by limiting the amounts transacted and the type of available transactions. This publication has been prepared for general guidance on matters of interest for the personal use of the reader. Questions and Answers: ‘Know Your Customer’ quick reference guide Q6.. You should not act upon the information contained in this publication without obtaining specific professional advice. and. information Q7. what are the various thresholds in place? A8. What are the high level requirements around beneficial ownership (identification and verification)? A11. the supervised entities must report to UIF-Peru the following situations: a) Clients operations which amounts to USD10. A5.org/countries/n-r/peru/ . No representation or warranty (express or implied) is given as to the accuracy or completeness of the information contained in this publication. and. PricewaterhouseCoopers LLP. copy of checks. the supervised entity must report any transaction which amounts to USD2. In accordance to SBS Resolution 838-2008. In case of fund transfer companies. amounts. In what circumstances are reduced/simplified due diligence arrangements available? A12. profession or occupation and domicile.500 (or its equivalent in PEN) or any other higher amount. The requirement is to verify the identity of customers who are regulated on Supreme Decree 018-2006-JUS. among others. and legal representative information (complete surname and name. currency. including dates. which was not modified. its members. b) Operations executed in one or more offices of the supervised entity in favour of the same person. Q12. or refraining to act. In case of fund transfer companies. to the extent permitted by law. PricewaterhouseCoopers LLP. The Legislative Decree 1106 includes additional control mechanisms related to criminal law. reduced/simplified due diligence measures are applicable in cases where the products. including the following documentation: a) information relating to the product characteristics.000 (or its equivalent in PEN) or any other higher amount. Q13.000 (or its equivalent in PEN) or any other higher amount. All rights reserved. its members. The application and impact of laws can vary widely based on the specific facts involved. responsibility or duty of care for any consequences of you or anyone else acting.

UIF-Peru of the SBS: http://www. in reliance on the information contained in this publication or for any decision based on it. article 9. services and distribution channels mitigate the risks by limiting the amounts transacted and the type of available transactions. or implied) is given as to the accuracy or completeness of the information contained in this publication. and must evaluate the quality of the AML / CFT System in the correspondent bank and the compliance of UIF-Peru regulations. are individuals or legal entities.sbs. © 2009 PricewaterhouseCoopers. article 9. A12. b) Trusts. article 9. Reporting Q18. Q15.  . employees and agents do not accept or assume any liability. b) report in which is defined the commercial and operative design of the product. especially in correspondent banks domiciled in countries with strict regulations or tax havens.2.with money You should notlaundering risks act upon the information contained in this publication without obtaining specific professional advice. as well as Credit Unions. 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. In accordance to SBS Resolution 838-2008. more orthan 5% of refraining theincapital to act. PricewaterhouseCoopers LLP. PEPs are also supervised by the Contraloria General de la República. reduced/simplified due diligence measures are applicable in cases where the products. e) Correspondent banking operations with foreign legal entities. f) prepared This publication has been Clientsforthat receive general fund guidance transfers on matters fromforcountries of interest the personalconsidered nonand use of the reader. The application and impact of laws can vary widely based on the specific facts involved. without banking supervision. legal entities  firms of in which a PEP is the owner of a percentage equal to or i) Clients under investigation of money laundering. are also supervised under the enhanced regime procedure. You should not act upon the information contained in this publication without obtaining specific professional advice. In what circumstances is additional due diligence required for non face-to-face transactions and/or relationships? A17. © 2009 PricewaterhouseCoopers. employees and agents do not accept g) Legal or assume anyentities in which aorPEP liability. and. They must identify and register the PEPs in case they execute transactional patterns that do not belong to their profile. article 11. ‘Know Your Customer’ quick reference guide including the following documentation: a) information relating to the product characteristics. with scarce banking supervision or countries under OFAC sanctions. the supervised entity must apply for an authorization from the SBS. including distribution channels. According to SBS Resolution 838-2008. which is the Peruvian agency in charge of the supervision of Public Official functions. 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 bank’s operations. or refraining to act. article 11. entity. The application and impact of laws can vary widely based on the specific facts involved.gob. What enhanced due diligence must be performed for correspondent banking relationships (cross-border banking and similar relationships)? A15. l) Legal entities in which their shareholders. to the extent permitted by law. its members. There are no additional due diligence required for non face-to-face transactions and/or relationships. According to SBS Resolution 838-2008.pe . This publication has been prepared for general guidance on matters of interest for the personal use of the reader. contribution or participation. enhanced due diligence measures are applicable to the following customers: a) National and foreign clients. Are relationships with shell banks specifically prohibited? A16. j) Clients related to individuals or legal entities under investigation or judicial procedures related to money laundering. To whom are Suspicious Activity Reports (SARs) made? Please include a link to their website. A18. In accordance to SBS Resolution 838-2008. According to SBS Resolution 838-2008. responsibility duty ofiscare theforowner of the amount any consequences equal of you or anyonetoelse or acting. to the extent permitted by law. “PricewaterhouseCoopers” refers to the network of member firms of PricewaterhouseCoopers International Limited. Questions In order and to applyAnswers: for the reduced/simplified due diligence arrangements. c) risk Management Program applicable to the product. especially the ones incorporated in tax havens or in countries . the supervised entities are entitled to carry out an enhanced regime procedure for PEPs. Q14. In what circumstances is additional due diligence required for Politically Exposed Persons (‘PEPs’)? A14. Q16. PricewaterhouseCoopers LLP. All rights reserved. responsibility or duty of care for any consequences of you or anyone else acting. reliance on contribution the information or in this contained participation publication or for any decision based on it. among other special mechanisms.. its members. more than the 5% of its capital stock. 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. Q17.1. and. corporations under Financial System Regulations. and has a high risk of money laundering or financing terrorism. precedent crimes and/or financing terrorism. In this case. PricewaterhouseCoopers International shareholders All rights more than 5% each Limited. non domiciled. “PricewaterhouseCoopers” capital of which is astock separate ofand administrators to the network ofofmember theindependent referred legal legalentity. professional advice. k) Clients with bank accounts in Foreign Currency according to the amounts mentioned in A8. of the or associates andrefers reserved. each of which is a separate and independent legal entity. precedent crimes and/or financing terrorism. and does not constitute professional advice. In what circumstances are enhanced customer due diligence measures required? A13. d) PEPs.2. m) Other customers with unusual or suspicious operations. partner or associates that have directly or indirectly. h) Partners. must execute policies and procedures related to the prevention or detection of unusual and suspicious operations carried out between national or foreign legal entities. c) Non domiciled companies. Country by country comparison of high level Know Your Customer and Anti-Money Laundering information Q13. No representation or warranty (express or implied) is given as to the accuracy or completeness of the information contained in this publication. cooperative countries does not constitute by GAFI. No representation or warranty (express and/or financing terrorism. stock.

Questions and Answers: ‘Know Your Customer’ quick reference guide Country by country comparison of high level Know Your Customer and Anti-Money Laundering information Q19. Q20. We’re a network of firms in 158 countries with more than 180. constituteTell us what matters professional advice. stipulates that regulated entities are requested to use automated Suspicious Transaction Monitoring Technology (its acronym in Spanish is ROSEL) to report suspicious transactions. Law 27693.pwc.000 people who This publication has been prepared for general guidance on are committed matters to delivering of interest quality use for the personal in assurance.pe/repositorioaps/0/2/jer/esta_transparenciaoperativa/2012/octubre_2012. Q24. general guidance and. PwC does do not accept or assume PricewaterhouseCoopers International Limited. Is there a requirement to obtain authority to proceed with a current/ongoing transaction that is identified as suspicious? A24. cash transactions above a certain threshold. to the accuracy or completeness of the information contained in this publication. Are there any penalties for non compliance with reporting requirements e. responsibility or duty the information of care for contained anypublication in this consequences of you without or anyone obtaining else acting. There are no limitations related to this aspect. on to the extent matters permitted of interest only.byand law. and advisory does notservices. in case the transaction is suspicious or unusual. There are no local regulations related to this matter. Q23. Are there any requirements (legal or regulatory) to use automated Suspicious Transaction monitoring technology? A23. No representation or warranty (express or implied) is given as to the accuracy or completeness of the information This publication has been contained prepared for in this publication. responsibility or duty of “PricewaterhouseCoopers” thisofpublication each which is a or for any and separate decision caretofor refers based on independent any the consequences network of member it. it must be reported. tipping off? A22.sbs. Once the transaction is executed. What was the volume of SARs made to the authorities in the most recent year? Please state the GDP for the equivalent year.does PricewaterhouseCoopers LLP. in any liability. to the extent permitted by law. Does the local legislation allow transactions to be monitored outside the jurisdiction? A25. international wire transfers. contained in this publication without obtaining specific professional advice.? A20. tax and of the reader. Moreover. article 11 stipulates the definition of suspicious and unusual transactions.g. Are there any obligations to report anything more than suspicious transactions e. All rights reserved. its not constitute professional members. specific or refraining professional advice.543 SARs (http://www. and. PwC helps organisations and individuals create the value they’re looking for. Yes. advice.com. or refraining to act.gob. © 2009 PricewaterhouseCoopers. A19. in reliance on the information contained . Volume of SARs: January to October 2012 – 2. The application and impact of laws can vary widely based on the specific facts involved. Q22. entity. . the supervised entity must report the operation and the customers’ information.toNoact. However. Are there any de-minimis thresholds below which transactions do not need to be reported? A21.to Youyoushould and find notout act more upon by thevisiting us at information www. article 9 stipulates the operations to be reported according to the amounts mentioned in A8. Law 27693. employees You should not actand upon agents do not accept or assume any liability. Q21. Article 1 of SBS Resolution Nº 9810-2011. other transactions etc. Penalties for non compliance with Law 29038 requirements are detailed on SBS Resolution 1782-2007. Please see A8. unusual transactions.g.pdf) GDP data is not available for this specific period. legal of firms you or  ofanyone else acting. in reliance onorthe representation information warranty contained (express in thisis given as or implied) publication or for any decision based on it. Q25.

com / viviana. please find a link to a relevant report (if publicly available). its members.seprelad. member firms of PricewaterhouseCoopers or refraining to act. No member firm is © 2009 PricewaterhouseCoopers. A4. Is there a requirement to retrospectively verify the identity of customers before the date the new AML regime was introduced? A5. Q6. No.com Tel: +595 21 445003 General Q1. and does not constitute professional advice. as the context requires. information contained in this or. No. distribution without or duty the permission of care for any of PwC. where available.gov. publication or forindividual member any decision basedfirms of the PwC network. Is there any practical guidance provided to firms by public authorities regarding AML requirements. You should not act upon the information contained in this publication without obtaining specific professional advice. In what year did the relevant AML laws and regulations become effective? A1. PwCIL does not provide any services on it. No representation or warranty (express or implied) is given as to the accuracy or completeness of the information contained in this publication.000. If the AML laws and/or regulations became effective in the last 2 years.py/ Q4. Asunción January 2013 Email: ruben. 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. casinos.). N/A. 521 Last updated: Viviana González Edificio Internacional Faro – Piso 6. Each member firm is a separate legal entity and does not act as agent of PwCIL or any other member firm. (b) Other financial Services.com / justo. PricewaterhouseCoopers LLP.taboada@py. .Due diligence procedures are not required on transactions below USD10. do notAll rightsor accept reserved.pwc. Please include link to the regulator(s) website A3. This publication has been prepared for general guidance on matters of interest for the personal use of the reader.g. to clients. high value goods etc.baez@py. Q2. (c) Non financial sector (e. to the extent permitted by law. Secretaría de Prevención de Lavado de Dinero (SEPRELAT) www.gonzalez@py. Customer due diligence Q8. Are there minimum transaction thresholds. Who is the regulator for AML controls for: (a) Banking. The Design Group 21383 (01/13) network exercise of member of another firms firm’s member of  professional judgment or bind another member firm or PwCIL in any way. assumeNot anyfor furtherresponsibility liability. in reliance on the International Limited (PwCIL). what are the various thresholds in place? A8. Q3. beyond the FATF recommendations and local legislation? Please include link to website. . No. what were the requirements of the previous AML regime? A2. and. 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. No. under which customer due diligence is not required? If Yes. “PwC” of consequences refers you to or the network anyone elseofacting. Is a risk based approach approved by the local regulator(s)? A6.pwc. each of which is a separate and independent legal entity. or liable for the acts or omissions “PricewaterhouseCoopers” of any other refers the member firm nor can it control to the PricewaterhouseCoopers International Limited. responsible All rights reserved. Q5.pwc. employees and ©agents 2013 PwC.Questions and Answers: ‘Know Your Customer’ quick reference guide Country by country comparison of high level Know Your Customer and Anti-Money Laundering information Paraguay Key contact: Rubén Taboada /Justo Báez / Postal address: General Díaz Nro. Q7. A7. 1997. The application and impact of laws can vary widely based on the specific facts involved.

telephone number. No. there are some documents that can be provided as copies. You should not act upon the information contained in this publication without obtaining specific professional advice. b) when the financial institution has doubts about the final beneficiary. in reliance on the information contained in this publication or for any decision based on it. as well as keeping up to date computer platforms. made? Please include a link to their website. and. . Enhanced due diligence arrangements are required for transactions above the USD10. Legal entities: Entity name. profession. its members. only that documents are not required for operations below USD10. telephone number. which is the Taxpayers Identification Number. In what circumstances is additional due diligence required for non face-to-face transactions and/or relationships? A17. In what circumstances are reduced/simplified due diligence arrangements available? A12. for legal entities. However. commercial references. The application and impact of laws can vary widely based on the specific facts involved. and entity constitutive documents. or refraining to act. which is the Taxpayers Identification Number). Q13. what are the requirements around independent verification or authentication? A10.Questions and Answers: ‘Know Your Customer’ quick reference guide Country by country comparison of high level Know Your Customer and Anti-Money Laundering information Q9. The law and its procedures define minimum requirements to identify customers: Individuals: birth date. and commercial references. shareholders list. “PricewaterhouseCoopers” refers to the network of member firms of Q18. home and business address. National Identification number (cédula de identidad) or passport number. financial institutions should always verify original identification documents.its operations must be approved by the highest authority of institutions to establish due diligence procedures to apply. What enhanced due diligence must be performed for correspondent banking relationships (cross-border banking and similar relationships)? A15. executives list.  . nationality. No representation or warranty (express or implied) is given as to the accuracy or completeness of the information contained in this publication. Q12. employees and Reporting agents do not accept or assume any liability. financial or industrial transactions in a location where they have no operations. each are Suspicious of which Activity is a separate Reports (SARs)and independent legal entity. On account transfers have correspondent evidence that preventative measures have been implemented and due diligence procedures performed on transfers. second degree of affinity. Q14. 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. Registro Unico de Contribuyente (RUC) if applicable. Are relationships with shell banks specifically prohibited? A16. © 2009 PricewaterhouseCoopers. occupation.000. including spouses. PricewaterhouseCoopers To whomInternational Limited. relatives and relatives up to fourth degree of consanguinity. No requirements are established around verification of this data. Q10. Where copies of identification documentation are provided.000 threshold. or c) when the customer engages in commercial. In what circumstances are enhanced customer due diligence measures required? A13. PricewaterhouseCoopers LLP. Q11. The correspondent must be approved by the highest authority of the institution. marital status and spouse’s name (if applicable). it must know the nature of the activities of the correspondent. Regístro Unico de Contribuyente (RUC). Q16. and does not constitute professional advice. activity. There are specific requirements to classify the customer as high risk . What are the high level requirements around beneficial ownership (identification and verification)? A11. Nonprofit organisations are also included. What are the high level requirements for verification of customer identification information (individuals and legal entities)? A9. 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. business address. In what circumstances is additional due diligence required for Politically Exposed Persons (‘PEPs’)? A14. Q17. if those copies are certified by a notary public officer. Q15. to the extent permitted by law. No specific procedures or guidance exist on this situation. responsibility or duty of care for any consequences of you or anyone else acting. and evaluate the policies and procedures to prevent money laundering and terrorist financing implemented by the correspondent. This publication has been prepared for general guidance on matters of interest for the personal use of the reader. According to law. All rights reserved.

Information on the volume of SARs is not publicly available. and does not constitute professional advice. Are there any obligations to report anything more than suspicious transactions e. This publication has been prepared for general guidance on matters of interest for the personal use of the reader.000. The application and impact of laws can vary widely based on the specific facts involved. responsibility or duty of care for any consequences of you or anyone else acting. “PricewaterhouseCoopers” PwC helps PricewaterhouseCoopers International Limited. Yes. Yes.py Q19. in reliance on the information contained in this publication or for any decision based on it. responsibility or duty of care for any consequences of you or anyone else acting. Are there any de-minimis thresholds below which transactions do not need to be reported? A21. people each ofwho which areiscommitted a separate to and refers tocreate organisations and individuals independent delivering the network legal quality of member the value entity. to the extent permitted by law. To whom are Suspicious Activity Reports (SARs) made? Please include a link to their website. unusual transactions. Q21. No representation or warranty (express or implied) is given as to the accuracy or completeness of the information contained in this publication. A19.com. A18. Tell us what matters to you and find out more by visiting us at www. No representation or warranty (express or implied) is given as to the accuracy or completeness of the information contained in this publication. No.  firms offor. All rights reserved.pwc. What was the volume of SARs made to the authorities in the most recent year? Please state the GDP for the equivalent year.Questions and Answers: ‘Know A17. Are there any requirements (legal or regulatory) to use automated Suspicious Transaction monitoring technology? A23.gov. Q20. and. We’re a network of firms in 158 countries with more than 180.seprelad.000 they’re looking tax and advisory services. and. © 2009 PricewaterhouseCoopers. Q25. . in reliance on the information contained in this publication or for any decision based on it. other transactions etc. Q24. This publication has been prepared for general guidance on matters of interest only. in assurance. Does the local legislation allow transactions to be monitored outside the jurisdiction? A25. Anything below USD10.g. or any other payment method). employees and agents do not accept or assume any liability. or refraining to act. . Are there any penalties for non compliance with reporting requirements e. Q23. The Secretaría de Prevención de Lavado de Dinero (SEPRELAT) www. as well as keeping up to date computer platforms. tipping off? A22. cash checks. international wire transfers. and does not constitute professional advice. Yes. exchanges. or refraining to act. PricewaterhouseCoopers LLP. to the extent permitted by law. You should not act upon the information contained in this publication without obtaining specific professional advice. No.? A20. Institutions must also report suspicious transactions. Q22. cash transactions above a certain threshold. You should not act upon the information contained in this publication without obtaining specific professional advice. Your Customer’ quick reference guide 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 physical remittance of money.g. its members. Country by country comparison of high level Know Your Customer and Anti-Money Laundering information Reporting Q18. PwC does do not accept or assume any liability. fund transfer operations to and from other countries (transfers. Is there a requirement to obtain authority to proceed with a current/ongoing transaction that is identified as suspicious? A24.

Some AML regulations became effective in the last two years. In what year did the relevant AML laws and regulations become effective? A1. assumeNot anyfor furtherresponsibility liability. 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. PwCIL does not provide any services on it. as the context requires. Q3. Rincón del Bosque sophie.demier@mx. information contained in this or. member firms of PricewaterhouseCoopers or refraining to act. 573 January 2013 Email: martin. Who is the regulator for AML controls for: (a) Banking. No representation or warranty (express or implied) is given as to the accuracy or completeness of the information contained in this publication. each of which is a separate and independent legal entity. Please include link to the regulator(s) website . to clients.montealegre@mx. No member firm is © 2009 PricewaterhouseCoopers. do notAll rightsor accept reserved. 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. . This publication has been prepared for general guidance on matters of interest for the personal use of the reader. employees and ©agents 2013 PwC.pwc.g. In addition. its members.). PricewaterhouseCoopers LLP. You should not act upon the information contained in this publication without obtaining specific professional advice. and does not constitute professional advice.F. Q2. casinos. responsible All rights reserved. There are different standards for each type of financial institution. publication or forindividual member any decision basedfirms of the PwC network. (c) Non financial sector (e. Prior to 2011 SOFOMs were not subject to AML regulations. to the extent permitted by law. (b) Other financial Services. “PwC” of consequences refers you to or the network anyone elseofacting. 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.Questions and Answers: ‘Know Your Customer’ quick reference guide Country by country comparison of high level Know Your Customer and Anti-Money Laundering information Mexico Key contacts: Martin Montealegre / Sophie Postal address: Last updated: Demier Mariano Escobedo No. distribution without or duty the permission of care for any of PwC. they previously were subject to the general provisions of The General Organizations with Auxiliary Credit Activity. México D. mainly to regulate the activity of the Multiple Purpose Financial Societies (SOFOMs) and Credit Unions. or liable for the acts or omissions “PricewaterhouseCoopers” of any other refers the member firm nor can it control to the PricewaterhouseCoopers International Limited.com / Col. Each member firm is a separate legal entity and does not act as agent of PwCIL or any other member firm. The Design Group 21383 (01/13) network exercise of member of another firms firm’s member of  professional judgment or bind another member firm or PwCIL in any way. In the case of the Credit Unions. what were the requirements of the previous AML regime? A2.com CP 11580. in reliance on the International Limited (PwCIL). Tel: +52 (55) 5263 5775 / +52 (55) 5263 MÉXICO 5462 General Q1.pwc. The application and impact of laws can vary widely based on the specific facts involved. high value goods etc. If the AML laws and/or regulations became effective in the last 2 years. and.

its members. what were the requirements of the previous AML regime? A2. Management of securities or assets 3. Management of bank accounts. mainly to regulate the activity of the Multiple Purpose Financial Societies (SOFOMs) and Credit Unions. they previously were subject to the general provisions of The General Organizations with Auxiliary Credit Activity. retrospectively verifyThe theapplication identityand of impact of laws before customers can vary widely based the date on new the the specific AMLfacts involved. depending on the type of financial institution. creditand The application or impact prepaid cards of laws andwidely can vary travelers based checks on the specific facts involved. via the Official Journal of the Federation publishes practical guidance to firms regarding AML requirements and best practices for AML prevention. A4. in reliance on the information contained in this publication or for Theanyfinancial decision based on it. to the extent permitted by law. employees and agents do not accept or assume any liability. In addition. merge. This publication has been prepared sweepstakes for general guidance onor gambling matters games of interest for the personal use of the reader.shcp.  Armor-plating services Professional service. Please include link to the regulator(s) website A3. National Retirement Savings System Commission) Regulated Institution Retirement Fund Managers Regulator 4: Secretaría de Hacienda y Crédito Público (SHCP. when preparing and performing on behalf of a third person any of the following operations: 1. de merge. marine or terrestrial vehicles © 2009 PricewaterhouseCoopers. casinos. CNBV) Taking into account that the prevention of crime starts with educating and diffusing a culture of prevention.). You should not act upon the information contained in this Is publication without obtainingto there a requirement specific professional advice. This publication has been prepared for general guidance on matters of interest for the personal use of the reader. Some AML regulations became effective in the last two years. SHPC) The SHCP has a section of FAQ´s aimed at fomenting a culture of AML prevention in financial institutions as well as non-financial institutions. Is there any practical guidance provided to firms by public authorities regarding AML requirements. and does not constitute professional advice. employees and agents do not accept or assume any liability. Country by country comparison of high level Know Your Customer and Anti-Money Laundering information Q3. “PricewaterhouseCoopers” refers to the network of member firms of TransferLimited. Who is the regulator for AML controls for: (a) Banking. the CNBV created the present section with the purpose of educating the public in a practical way. http://www. responsibility or duty of care for any consequences of you or anyone else acting. Selling of precious metals and stones. Constitution. Contests. in reliance on the information contained in this Buying publication or for any decision based onandit. operation and management of corporations Public Notaries Forwarding agent Non Profit Organizations Leasing of real estate Q4.g.aspx .mx/PrevencionDeLavadoDeDinero/Paginas/Cultura. where available. (c) Non financial sector (e. its members.has historically applied KYC policies. National Insurance and Surety Institution) Regulated Institutions Insurance Institutions Surety Institutions Regulator 3: Comisión Nacional de Sistemas de Ahorro para el Retiro (CONSAR. regime was Nointroduced? representation or warranty (express Q5.cnbv. high value goods etc. Prior to 2011 SOFOMs were not subject to AML regulations.gob. in a independent manner. National Banking and Securities Commission) Regulated Institutions Commercial banks Development Banking Institutions Limited Purpose Financial Society (SOFOL) Broker Houses Society´s Managing Mutual Funds (Sociedades Operadoras de Sociedades de Inversión) Distribution Society´s of Mutual Fund Shares Financial Lessor Financial Factoring companies General Deposit Warehouses Credit Unions Society´s 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: Comisión Nacional de Seguros y Fianzas (CNSF. You should not act upon the information contained in this publication Issuance andspecific without obtaining marketing of service professional advice. In the case of the Credit Unions. about different aspects related to AML/CFT. There are different standards for each type of financial institution. PricewaterhouseCoopers LLP. and. Regulator 1: Comisión Nacional Bancaria y de Valores (CNBV. In Mexico. No representation or warranty (express or implied) is given as to theGranting accuracy orloans completeness of the information contained in this publication. savings or assets 4. The Ministry of Finance and Public Credit (Secretaria de Hacienda y Credito Publico. and. PricewaterhouseCoopers International or custody each ofof money which or securities is a separate and independent legal entity. (b) Other financial Services. Purchase or sell of real estate 2. and does not constitute professional advice. http://www. SHPC). or implied) is given as to the accuracy or completeness of the information contained in this publication. to the extent permitted by law. jewelry watches and art Sale or lease of aircraft. Q2. PricewaterhouseCoopers LLP. Ministry of Finance and Public Credit (Secretaria de Hacienda y Credito Publico. All rights reserved.gob. cards. If the AML laws and/or regulations became effective in the last 2 years. or refraining to act. in October 2012 Mexican Questions and Answers: authorities issued the new Federal Law for the Prevention and Identification of Operations with Illegal Resources to regulate Designated ‘Know Your Customer’ quick reference guide non-Financial Businesses and Professions. or refraining to act. beyond the FATF recommendations and local legislation? Please include link to website.mx/INTELIGENCIA_FINANCIERA/Paginas/Preguntas_Frecuentes.aspx National Banking and Securities Commission (Comisión Nacional Bancaria y de Valores. Secretary of Finance and Public Credit) Actividades vulnerable (Designated non-Financial Businesses and Professions) . but under an internal controls approach rather than for the purpose of anti-money sector A5. . responsibility or duty of care for any consequences of you or anyone else acting. various organisms regulate AML controls.

CNBV) ‘Know Your Customer’ quick reference guide Taking into account that the prevention of crime starts with educating and diffusing a culture of prevention. Each of the different entities that are subject to AML general provisions as mentioned in answer 3 consider different transaction thresholds. There is not an official risk approach model established by the authority. its members.cnbv.mx/PrevencionDeLavadoDeDinero/Paginas/Cultura. any birth responsibility or duty of care for any consequences of you or anyone else acting. depending on the type of products and services that they each provide. Q6. in reliance on the information contained in this publication or for any c) decisionNationality based on it. but the general provisions require the entity to integrate a model based on parameters which classifies their clients depending on the risk they represent. Mexico was initially evaluated by the GAFI in 2008. but in general they include: . or refraining to act. This publicationInhas thebeen case of individuals: prepared for general guidance on matters of interest for the personal use of the reader. No representation or warranty (express a) Full name or implied) is given as to the accuracy or completeness of the information contained in this publication. The application and impact of laws can vary widely based on the specific facts involved. and does not constitute professional advice. information All rights reserved. a) Mutual Evaluation Report of Mexico by GAFI a. the CNBV created the present section with the purpose of educating the public in a practical way. since then GAFI and GAFISUD have issued monitoring reports in 2009.gob. Q7.aspx Country by country comparison of high level Know Your Customer and Anti-Money Laundering information Q5. please find a link to a relevant report (if publicly available). Requirements for customer identification information may vary according to financial entities. under which customer due diligence is not required? If Yes.aspx Questions Nationaland Answers: Banking and Securities Commission (Comisión Nacional Bancaria y de Valores. 2010. about different aspects related to AML/CFT.mx/INTELIGENCIA_FINANCIERA/Paginas/Preguntas_Frecuentes.gob. employees and agents do not accept b) Date or assume ofliability. but under an internal controls approach rather than for the purpose of anti-money laundering prevention. What are the high level requirements for verification of customer identification information (individuals and legal entities)? A9. You should not act upon the information contained in this publication without obtaining specific professional advice. PricewaterhouseCoopers LLP. to the extent permitted by law. http://www. October 2010 b. A7. 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. http://www. and. The financial sector has historically applied KYC policies. Taxpayer “PricewaterhouseCoopers” refers to the network of member firms of each registration (RFC)and independent legal entity. d) Employment © 2009 PricewaterhouseCoopers. October 2012 c) Monitoring report by GAFISUD June 2009 December 2009 June 2010 December 2010 June 2011 December 2011 June 2012 Customer due diligence Q8. establishing at least two levels of risk: low and high risk customers. SHPC) The SHCP has a section of FAQ´s aimed at fomenting a culture of AML prevention in financial institutions as well as non-financial institutions.shcp. 2011 and 2012. Are there minimum transaction thresholds. Is a risk based approach approved by the local regulator(s)? A6. Ministry of Finance and Public Credit (Secretaria de Hacienda y Credito Publico. e) International PricewaterhouseCoopers Code of Limited. Q9. October 2011 c. 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 . 2008 b) Monitoring report by GAFI a. what are the various thresholds in place? A8. Is there a requirement to retrospectively verify the identity of customers before the date the new AML regime was introduced? A5.

employees and http://www. All rights reserved. some of which include black lights and special training courses for detecting false Ids. You should not act upon the information professional contained in this publication without obtaining specific professional advice.aspx agents do not accept or assume any liability. When the client is considered a low risk client. To whom are Suspicious Activity Reports (SARs) made? Please include a link to their website. responsibility or duty of care for any consequences of you or anyone else acting. The application and impact of laws can vary widely based on the specific facts involved. what are the requirements around independent verification or authentication? A10. Copies of identification documentation are provided at the initial stage of the commercial relationship.hacienda. A18. Q11. Q16. according to AML General Provisions. Mexican regulation does not require that enhanced due diligence be performed for correspondent banking relationships. each ofmust bea separate which is performed for correspondent and independent legal entity. some institutions are implementing authenticity measures. Where copies of identification documentation are provided. in reliance on the information contained in this publication or for any decision based on it. PricewaterhouseCoopers LLP. banking relationships  (cross-border banking and similar relationships)? A15. SHPC). Q12. and see theconstitute does not following link: advice. . or refraining to act. its members. and. Reporting Q18. 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. Reports are sent to the Secretaría de Hacienda y Crédito Público (SHCP) via the respective regulatory bodies of each entity (see answer 3). 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 Q14. © 2009 PricewaterhouseCoopers. Are relationships with shell banks specifically prohibited? A16. a) Client personal interview b) Visits to clients address c) Criteria to classify the risk a client represents. In what circumstances are reduced/simplified due diligence arrangements available? A12. some institutions require additional information to support that transaction.gob. What enhanced PricewaterhouseCoopers due International diligence Limited. “PricewaterhouseCoopers” refers to the network of member firms of Q15. Q17. to the extent permitted by law. In what circumstances is enhanced-customer due diligence measures required? A13. What are the high level requirements around beneficial ownership (identification and verification)? A11. No representation or warranty (express or implied) is given as to the accuracy or completeness of the information contained in this publication. Generally entities that respond to a foreign corporate base have stricter AML controls. While there is no legal requirement around independent verification or authentication of identification documentation. Yes. Requirements for the identification of the beneficiary may vary depending on the type of client and the institution that requires them. Q13. Each entity establishes its own criteria and mechanisms of control and prevention.mx/LASHCP/MarcoJuridico/InteligenciaFinanciera/Paginas/ListaPersonasPoliticamenteExpuestas. The Ministry of Finance and Public Credit (Secretaría de Hacienda y Crédito Público. In what circumstances is additional due diligence required for Politically Exposed Persons (‘PEPs’)? A14. 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. reader. provides the public with a list of criteria for . In the case of corporations: a) Corporate name b) Economic activity or social activity c) Nationality d) Code of taxpayer registration (RFC) Questions and Answers: e) Serial number of Advanced Electronic Signature f) Proof of address ‘Know Your Customer’ quick reference guide g) Telephone number h) E-mail i) Date of constitution Country by country comparison of high level Know Your Customer and Anti-Money Laundering information Q10. at the time the Client File is created. Depending on the amount of the transaction. In what circumstances is additional due diligence required for non face-to-face transactions and/or relationships? A17.

Are relationships with shell banks specifically prohibited? A16. employee or agent of the entity. there are thresholds for relevant operations. international fund transfers and US dollar transactions above which a suspicious activity report must be filed. Q19. officer. Your Customer’ quick reference guide Depending on the amount of the transaction. PricewaterhouseCoopers LLP. What was the volume of SARs made to the authorities in the most recent year? Please state the GDP for the equivalent year. employees and agents do not accept or assume any liability. according to AML General Provisions. employee or agent of the entity has repeatedly participated in operations that have been reported as unusual transactions. without reasonable cause a director. or refraining to act. To whom are Suspicious Activity Reports (SARs) made? Please include a link to their website. and the activity the person in question actually carries out. please contact Martin or Sophie In addition. international wire transfers. cash transactions above a certain threshold. Yes. Questions and Answers: Q17. You should not act upon the information contained in this publication without obtaining specific professional advice. “PricewaterhouseCoopers” refers to the network of member firms of PricewaterhouseCoopers International Limited. A19. A18. In what circumstances is additional due diligence required for non face-to-face transactions and/or relationships? ‘Know A17. b) When. officer.g. maintains a standard of living well above that would correspond. All rights reserved. cash transaction. without reasonable cause there is a gap between the functions that a manager. No representation or warranty (express or implied) is given as to the accuracy or completeness of the information contained in this publication. For further details. according to the earnings of the person in question. In most financial entities. responsibility or duty of care for any consequences of you or anyone else acting. Country by country comparison of high level Know Your Customer and Anti-Money Laundering information Reporting Q18. Q16. This publication has been prepared for general guidance on matters of interest for the personal use of the reader. other transactions etc. unusual transactions. its members. Reports are sent to the Secretaría de Hacienda y Crédito Público (SHCP) via the respective regulatory bodies of each entity (see answer 3). in reliance on the information contained in this publication or for any decision based on it.  Q20. a transaction is to be considered suspicious in the follow circumstances: a) When a manager. c) When. and does not constitute professional advice. each of which is a separate and independent legal entity. Unusual Transaction Reports Worrisome Internal Operation Relevant Transaction Reports U. Are there any obligations to report anything more than suspicious transactions e. some institutions require additional information to support that transaction. employee or agent should do. and. The application and impact of laws can vary widely based on the specific facts involved. officer.S dollars Cash Transactions Report . to the extent permitted by law.? A20. . © 2009 PricewaterhouseCoopers.

unusual transactions. international fund transfers and US dollar transactions above which a suspicious activity report must be filed. officer. Yes. unusual operation. cash transaction.? A20. Q25. In most financial entities. We’re a network of firms in 158 countries with more than 180. there are thresholds for relevant operations. without reasonable cause there is a gap between the functions that a manager. No.else of you or anyone tipping acting. or refraining to act.Questions and Answers: ‘Know Your Customer’ quick reference guide Country by country comparison of high level Know Your Customer and Anti-Money Laundering information Q20. and does not constitute professional advice. information on significant transactions reports. The application and impact of laws can vary widely based on the specific facts involved.g. encrypt and securely transmit to the secretary. Entities must have automated systems which must have the following functions: a) Maintain and update data to allow consultation of the records. No representation or warranty (express or implied) is given as to the accuracy or completeness of the information contained in this publication. and. Is there a requirement to obtain authority to proceed with a current/ongoing transaction that is identified as suspicious? A24. in reliance on the information contained in this publication or for any decision based on it. Are there any minimum thresholds below which transactions do not need to be reported? A21. to the extent permitted by law. below which a suspicious activity report does not need to be filed. “PricewaterhouseCoopers” refers to the network of member firms of A22. employee or agent of the entity. For further information. encode. maintains a standard of living well above that would correspond. cash transactions above a certain threshold. and the activity the person in question actually carries out. . employee or agent of the entity has repeatedly participated in operations that have been reported as unusual transactions. its members. b) When. In most financial entities. Q21. international wire transfers. according to the earnings of the person in question. No representation or warranty (express or implied) is given as to the accuracy or completeness of the information contained in this publication. For further details. This publication has been prepared for general guidance on matters of interest only. Q24. responsibility or duty of carewith reporting for any requirements consequences e.g. there are thresholds for relevant operations.  Q23. through the commission. PricewaterhouseCoopers LLP. and international transfers.pwc. Are there any obligations to report anything more than suspicious transactions e.com. b) Generate. c) When. employee or agent should do. PwC does do not accept or assume any liability. cash transaction. please contact Martin or Sophie In addition. You should not act upon the information contained in this publication without obtaining specific professional advice. responsibility or duty of care for any consequences of you or anyone else acting. without reasonable cause a director. officer. h) Serve as a means for the agency staff so they can report to internal areas that they determine. and. j) Run an alert system on operations that intend to carry out with people linked to terrorism or its financing. © 2009 PricewaterhouseCoopers. d) Detect and monitor the operations performed by a client or by the same user from those indicated. officer. You should not act upon the information contained in this publication without obtaining specific professional advice.off? or refraining to act. according PricewaterhouseCoopers to AML International General Limited. i) Maintain security schemes of information processed. a transaction is to be considered suspicious in the follow circumstances: a) When a manager. This publication has been prepared for general guidance on matters of interest for the personal use of the reader. or other illegal activities. c) Classify types of operations or financial products offered by entities to their customers or users. Does the local legislation allow transactions to be monitored outside the jurisdiction? A25. Yes. Tell us what matters to you and find out more by visiting us at www. in reliance on the information contained in this publication or for any decision based on it. PwC helps organisations and individuals create the value they’re looking for. transactions. each of which is a separate and independent legal entity. Are there any requirements (legal or regulatory) to use automated Suspicious Transaction monitoring technology? A23. employees and Q22. please contact Martin or Sophie. g) Maintain historical records of possible worrisome internal operations and Unusual Operations. All rights reserved. Provisions. in a safe. f) Group on a consolidated basis of the different contracts to the same client. e) Run warning systems that contribute to the detection and monitoring of suspicious activity analysis. to the extent permitted by law. and does not constitute professional advice. Are there agents do not accept any any or assume penalties for non compliance liability. other transactions etc. according to General provisions.000 people who are committed to delivering quality in assurance. confidential and auditable way. tax and advisory services. international fund transfers and US dollar .

). agents do notAll rightsor accept reserved.boj.jm Q4. employees and © 2013 PwC. PricewaterhouseCoopers LLP. high value goods etc.org/external/pubs/ft/scr/2006/cr06156. firms of PricewaterhouseCoopers or refraining to act. or liable for the acts or omissions “PricewaterhouseCoopers” of any other refers the member firm nor can it control to the PricewaterhouseCoopers International Limited. You should not act upon the information contained in this publication without obtaining specific professional advice.imf. and does not constitute professional advice. what are the various thresholds in place? . they generally encourage companies to identify and monitor key company risks to ensure that anti money laundering detection and reporting guidelines are being followed. responsible All rights reserved. information contained in this or. Q5. and. distribution without or duty the permission of care for any of PwC. Is there any practical guidance provided to firms by public authorities regarding AML requirements. Kingston. Please include link to the regulator(s) website A3. Financial Services Commission (FSC) www. assumeNotanyfor furtherresponsibility liability. If the AML laws and/or regulations became effective in the last 2 years.s. Q3.com Scotiabank Centre. Jamaica General Q1. Each member firm is a separate legal entity and does not act as agent of PwCIL or any other member firm. The application and impact of laws can vary widely based on the specific facts involved.although the regulations do not specifically approve a risk based approach.com .org. The Design Group 21383 (01/13) network exercise of of member another firms of member  firm’s professional judgment or bind another member firm or PwCIL in any way. No member firm is © 2009 PricewaterhouseCoopers.O. under which customer due diligence is not required? If Yes. (c) Non financial sector (e. Who is the regulator for AML controls for: (a) Banking. please find a link to a relevant report (if publicly available).bartley@jm. Are there minimum transaction thresholds. to the extent permitted by law. publication or forindividual member any decision basedfirms of the PwC network.org. Q7. as the context requires.Questions and Answers: ‘Know Your Customer’ quick reference guide Country by country comparison of high level Know Your Customer and Anti-Money Laundering information Jamaica Key contact: Peta-Gaye Bartley Postal address: Last updated: Email: peta-gaye. A7. A4. where available. No representation or warranty (express or implied) is given as to the accuracy or completeness of the information contained in this publication. “PwC” of consequences refers you toor the network anyone elseof member acting. http://www. in reliance on the International Limited (PwCIL). Bank of Jamaica www. Is a risk based approach approved by the local regulator(s)? A6. 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. Box 372. beyond the FATF recommendations and local legislation? Please include link to website. (b) Other financial Services. The last Financial System Stability Assessment done by the IMF on Jamaica was in March 2006.g. what were the requirements of the previous AML regime? A2. each of which is a separate and independent legal entity. No . its members. Q2. 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.pdf.fscjamaica. Duke Street January 2013 Tel: +1 (0) 876 922 6230 P. In what year did the relevant AML laws and regulations become effective? A1. PwCIL does not provide any services on it. This publication has been prepared for general guidance on matters of interest for the personal use of the reader. Is there a requirement to retrospectively verify the identity of customers before the date the new AML regime was introduced? A5. The Financial Services Commission provides guidance on AML (revised March 30 2007) www. No. 1996 (amended 2007). . Customer due diligence Q8.natlaw. N/A.pwc. casinos. Q6. to clients.

Q13. for example passport. This publication has been Under theprepared Proceedfor general guidance of Crime (POCA)on matters of interest for2007. Q10. No representation or warranty (express or implied) is given as to the accuracy or completeness of the information contained in this publication. There are some institutions that are exempt from . major beneficiaries etc. what are the requirements around independent verification or authentication? A10. In what circumstances is additional due diligence required for Politically Exposed Persons (‘PEPs’)? . to the extent permitted by law. and. Where there are underlying principals. ‘Know A7. Questions and please find a linkAnswers: to a relevant report (if publicly available). for example more detailed information on the customer’s 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. and e) Copies of identification documents should be obtained from at least two directors. Verification of the institution is not needed for five types of eligible institutions. You be prepared forshould not act uponin transactions thecash information equal contained in this publication without obtaining specific professional advice. high commissions. Memorandum & Articles of Association. under which customer due diligence is not required? If Yes. “PricewaterhouseCoopers” refers to the network of member firms of PricewaterhouseCoopers International Limited. the Threshold and does not Transaction constitutemust Reports professional advice. PricewaterhouseCoopers LLP. submitting threshold transactions such as embassies. especially if the signatories are accustomed to acting on their instructions. Certificate of Incorporation. This publication has been prepared for general guidance on matters of interest for the personal use of the reader. date and place of birth. The threshold for remittance companies and cambio transactions are USD5. telephone directory or the voters poll. most recently filed annual return. In what circumstances are reduced/simplified due diligence arrangements available? A12. Your Customer’ quick reference guide The last Financial System Stability Assessment done by the IMF on Jamaica was in March 2006. the name and address of the customer should be verified by an independent source. For a partnership. the true nature of the relationship between the principals and the account signatories must also be established. Yes . Emphasis is placed on original documentation where available. Q7. Financial institutions are required to implement enhanced due diligence for transactions involving high risk activities. agents do not accept or assume any liability. the following amongst other documents may be obtained: a) Certificate of Incorporation. Regulations the personal use of the reader. what are the various thresholds in place? A8. firms should carry out verification in respect of the parties operating the account. a building society registered under the Building Societies Act. Appropriate enquiries should be performed on the principals. for example. In what circumstances are enhanced customers due diligence measures required? A13. the partnership agreement. You should not act upon the information contained in this publication without obtaining specific professional advice.imf. Q11.000 or implied) is given as to the accuracy or completeness of the information contained in this publication. controlling shareholders. address etc. Q14. each of which is a separate and independent legal entity.all transactions above the thresholds must be reported to the required institutions. 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. current utility bill. nationality. This requires stricter KYC procedures. in reliance on the information contained in this publication or for any decision based on it. 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. Are there minimum transaction thresholds. copies of powers of attorney or other authorities given by directors in relation to the company are required. directors. employees and respectively. Where copies of identification documentation are provided. What are the high level requirements for verification of customer identification information (individuals and legal entities)? A9. No representation or warranty (express to or exceeding threshold of USD15. In this context “principals” should be understood in its widest sense to include. monitor key company risks to ensure that anti money laundering detection and reporting guidelines are being followed. Individuals require a registered name. in some instances. its members. its members. to the extent permitted by law. All rights reserved. There is no specific information in local guidance which deals specifically with beneficial ownership.  Q9. identity card. a society registered under the Co- operative Societies Act and an insurance company registered under the Insurance Act. http://www. For large corporate accounts. The application and impact of laws can vary widely based on the specific facts involved. However. government agencies and statutory bodies. settlers. businesses. Country by country comparison of high level Know Your Customer and Anti-Money Laundering information Customer due diligence Q8. Q12. or refraining to act. The regulations do not specifically state what copies of documentation can be certified by external third parties. The application and impact of laws can vary widely based on the specific facts involved. responsibility or duty of care for any consequences of you or anyone else acting.org/external/pubs/ft/scr/2006/cr06156. foreign countries and linked accounts. employees and . What are the high level requirements around beneficial ownership (identification and verification)? A11. c) the most recent annual return filed with the Registrar.pdf. © 2009 PricewaterhouseCoopers. beneficial owners. PricewaterhouseCoopers LLP. They also require. an unincorporated business and companies. a financial institution licensed under the Financial Institutions Act. including a licensed bank. independent verification of the documentation presented by the customer. and does not constitute professional advice. and. As part of the verification process. b) Memorandum & Articles of Association. driving licence.000.000 and USD8.

No representation or warranty (express or implied) is given What as enhanced to the accuracy or completeness due of the information diligence must contained be performed forincorrespondent this publication. a) International PricewaterhouseCoopers Articles of due diligence All rights reserved. Q13. Q22. This publication has been prepared for general guidance on matters of interest for the personal use of the reader. “PricewaterhouseCoopers” refers to the network of member firms of PricewaterhouseCoopers International Limited. cash transactions above a certain threshold. members of the board of directors and management composition. each of which is a separate and independent legal entity. operative Societies Act and an insurance company registered under the Insurance Act. In what circumstances are enhanced customers due diligence measures required? Questions and Answers: ‘Know Your Customer’ quick reference guide A13. A15. Information on the volume of SARs not publicly available. Are there any de-minimis thresholds below which transactions do not need to be reported? A21. You should not act upon the information contained in this publication without obtaining specific professional advice. for example more detailed information on the customer’s 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. No. Financial institutions are required to implement enhanced due diligence for transactions involving Politically Exposed Persons ('PEPs').jm/fid Q19. Limited. and d) apply additional oversight to the PEP's account. employees and relationships)? Q15. The application and impact of laws can vary widely based on the specific facts involved. You should not act upon the information contained in this publication without obtaining specific professional advice. Also refer to A8 above. To whom are Suspicious Activity Reports (SARs) made? Please include a link to their website. relationships PricewaterhouseCoopers (cross-border banking LLP. Reporting Q18. in reliance on the information contained in this publication or for any decision based on it. Yes. In Jamaica. Country by country comparison of high level Know Your Customer and Anti-Money Laundering information Q14. A19. transactions over a certain threshold should be reported to the Financial Investigations Division. all suspicious transactions should be reported.g. b) understand the PEP’s anticipated account activity. Are relationships with shell banks specifically prohibited? A16. tipping off? . should be obtained “PricewaterhouseCoopers” 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. foreign countries and linked accounts. to the extent banking permitted by law. to the extent permitted by law. A18. Q16. and. other transactions etc. Financial institutions are required to implement enhanced due diligence for transactions involving high risk activities. All rights reserved. Are there any obligations to report anything more than suspicious transactions e. Q20. c) determine the PEP’s source of wealth. unusual transactions. or refraining to act. . employees and agents do not accept or assume any liability.anditssimilar members. Yes. All regulated entities must also: a) obtain adequate documentation regarding the PEP. This publication has been prepared for general guidance on matters of interest for the personal use of the reader. In what circumstances is additional due diligence required for Politically Exposed Persons (‘PEPs’)? A14. In accepting business from non face-to-face customers. responsibility or duty of care for any consequences of you or anyone else acting. The application and impact of laws can vary widely based on the specific facts involved. agents do not accept or assume any liability. businesses. in reliance on the information contained in this publication or for any decision based on it. PricewaterhouseCoopers LLP. The Financial Investigations Division. or refraining to act. Q17.gov.mof.g.? A20.  financial institution. What was the volume of SARs made to the authorities in the most recent year? Please state the GDP for the equivalent year. and. Measures to mitigate risk may include requisition of additional documents to complement those which are required for face-to-face customers. and does not constitute professional advice.  . and does not constitute professional advice. © 2009 PricewaterhouseCoopers. b) approval must be granted by senior management to open the account. The following enhanced © 2009 PricewaterhouseCoopers. No representation or warranty (express or implied) is given as to the accuracy or completeness of the information contained in this publication. In what circumstances is additional due diligence required for non face-to-face transactions and/or relationships? A17. such reports are referred to as the Suspicious Transactions Reports (STRs). its members. Q21. Association. responsibility or duty of care for any consequences of you or anyone else acting. This requires stricter KYC procedures. international wire transfers. 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. Are there any penalties for non compliance with reporting requirements e. http://www.

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. PwC helps organisations and individuals create the value they’re looking for. each of which is a separate and independent legal entity. in reliance PricewaterhouseCoopers LLP. etc.000 (RM Court). Yes there are penalties. Tell us what matters to you and find out more by visiting us at www. You should not act upon the information respect contained in this to without publication tippingobtaining off a company can beadvice. Q24. and does not constitute professional advice. facts involved. each of which is a separate and independent legal entity. threshold. All rights reserved.g. 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. ofextent and. A21. by law. This publication has been prepared for general guidance on matters of interest only. Failure to file suspicious transaction reports with the designated authority will attract up to 1 year imprisonment jail or JMD1 . NoPwC does do not representation or accept warrantyor(express assume any liability. of laws can vary widely based on the specific facts involved. and. and does not constitute professional advice. RM Court). In This publication has been prepared for general guidance on matters of interest for the personal use of the reader. No. Are there any requirements (legal or regulatory) to use automated Suspicious Transaction monitoring technology? © 2009 PricewaterhouseCoopers. negative publicity. Does the local legislation allow transactions to be monitored outside the jurisdiction? A25. PricewaterhouseCoopers LLP. or refraining to act. Questions and Answers: ‘Know Your Customer’ quick reference guide Q21. © 2009 PricewaterhouseCoopers. by country comparison of high level Know Your Customer and Anti-Money Laundering information Country Q22. Also refer to A8 above. No. transactions over a certain threshold should be reported to the Financial Investigations Division. Are there any penalties for non compliance with reporting requirements e. all suspicious transactions should be reported. We’re a network of firms in 158 countries with more than 180. “PricewaterhouseCoopers” refers to the network of member firms of PricewaterhouseCoopers International Limited.000 and impact(RM Court).000 people who are committed to delivering quality in assurance. Failure to file a threshold transaction report attracts a fine of up to JMD400. “PricewaterhouseCoopers” refers to the network of member firms of PricewaterhouseCoopers International Limited. in reliance on the information contained in this publication or for any decision based on it. its members.com.? A20. There is no requirement to obtain authority to proceed.ontothe widely based thespecific extent permitted by law. Failure to comply with the provision of the law may result in commercial prosecution. The application and impactcontained in this of laws can publication.pwc. Q25. to the extent permitted by law. No representation or warranty (express or implied) is given as to the accuracy or completeness of the information contained in this publication. Q23. .  . other transactions etc. responsibility or duty of care for any consequences of you or anyone else acting. international wire transfers. or refraining to act. to the you orpermitted anyone else acting. not constitute No representation professional or warranty advice.of you or anyone else acting. commercial losses. tax and advisory services. specific professional fined The up application to JMD600. Are there any de-minimis thresholds below which transactions do not need to be reported? No. employeescontained and in this publication agents do not accept or assume any liability. responsibility or duty or of for careany fordecision based on it. All rights reserved. million (Resident Magistrate. or implied) is given as to the accuracy or completeness of theresponsibility or duty of in information contained care thisfor any consequences publication. professional and does advice. in reliance on the information contained in this any consequences publication or for any decision based on it. Is there a requirement to obtain authority to proceed with a current/ongoing transaction that is identified as suspicious? A24. or refraining to act. tipping off? A22. vary and.  A23. its on the information members. employees and agents do not accept or assume any liability. Yes.

If the AML laws and/or regulations became effective in the last 2 years. to clients. casinos. what were the requirements of the previous AML regime? A2.is All given as reserved. the Superintendence of Finance of Colombia. This publication has been prepared for general guidance on matters of interest for the personal use of the reader.and as the agents requires. to thetonetwork the extent permittedfirms of member by law. 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. (c) Non financial sector (e. rights to the accuracy Not fororfurther completeness of the distribution information without contained the permission in this“PwC” of PwC. in other any reliance on thefirm. No representation or warranty (express ©or2013 implied) PwC. the Superintendent of Finance of Colombia issued External Circular No. Limited employees (PwCIL). or duty Eachof care forfirm member anyisconsequences a separate legalof entity you orandanyone does else acting.Questions and Answers: ‘Know Your Customer’ quick reference guide Country by country comparison of high level Know Your Customer and Anti-Money Laundering information Colombia Key contact: Steven Koegler Postal address: Last updated: Email: steven. . not act or refraining as agent of PwCILto or act. Is a risk based approach approved by the local regulator(s)? A6. refers and. Q3.superfinanciera. The 2009 regulation incorporates some new reporting standards that must be adhered to when reporting to the Regulator. regarding the implementation of the System for Preventing Assets Laundering and Terrorism Financing (SARLAFT) with a risk based approach.). 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. Are there minimum transaction thresholds. firms of theresponsibility PwC network. Yes – new regulation establishes the parameters for KYC procedures which incorporate the requirement to update a customers’ information. investigating unusual transactions and reporting any suspicious transactions to the relevant authorities. A7. Who is the regulator for AML controls for: (a) Banking. In 2008. PricewaterhouseCoopersInternational of PricewaterhouseCoopers LLP. 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. SARLAFT requirements are issued by the regulator. context do not accept or assume individual memberany liability. Q2. member firm nor can it control “PricewaterhouseCoopers” refers the exercise to the International Limited. No member firm is responsible or liable for the acts or omissions © 2009 PricewaterhouseCoopers.koegler@co. its members. A4.gov. what are the various thresholds in place? . Is there a requirement to retrospectively verify the identity of customers before the date the new AML regime was introduced? A5. In what year did the relevant AML laws and regulations become effective? A1. of another network of member member firms firm’s of  professional judgment or bind another member firm or PwCIL in any way. and does not constitute professional advice. publication. please find a link to a relevant report (if publicly available). Q7.g.pwc. Cundinamarca. Entities have to report to the Financial Information and Analysis Unit (UIAF) of Colombia Q4. Yes – new regulation has a risk based approach regarding AML. 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. 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. or. 022 2007. where available. Customer due diligence Q8. member information contained PwCIL does in thisany services not provide publication or for any decision based on it. PricewaterhouseCoopers The Design Group 21383 (01/13) of any other All rights reserved. 8th. (b) Other financial Services. Please include link to the regulator(s) website A3. Floor. The application and impact of laws can vary widely based on the specific facts involved.co/Normativa/NormasyReglamentaciones/cir007/cap11lavadodeactivos. January 2013 Tel: +571 6340528 or 6240555 ext 485 Bogotá. The main features of the SIPLA regulation included implementing adequate KYC procedures. Q6. under which customer due diligence is not required? If Yes. No.com Calle 100 No 11-A-35. http://www. each of which is a separate and independent legal entity. monitoring transactions.doc Q5. Colombia General Q1. You should not act upon the information contained in this publication without obtaining specific professional advice. high value goods etc.

than its members. activity and reason for sending the wire and beneficiary. under which customer due diligence is not required? If Yes. They must also implement follow up procedures for clients’ transactions. tax payment copy or yearly income certificate.000. This publicationYes has -been there are various prepared for generalthresholds depending guidance on matters on for of interest thethetype of transaction. Enhanced due diligence is required for PEPs. employees and . Customers should be able to demonstrate the source of income and ownership by way of a copy of a tax payment. and. 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. This also includes due diligence of deposit accounts which will be used by political parties and during political campaigns.g. Each time a PEP is identified. No representation or warranty (express or implied) is given as to the accuracy or completeness of the information contained in this publication. You should not act upon the information contained in this publication without obtaining specific professional advice. special insurance types. and does no customer not constitute due diligence professional forshould advice. Banks should comply with the minimum requirements of the regulations.  Q9. . All rights reserved. Q14. The application and ofif laws and impact a signed can varysignature widely basedcard forspecific on the an account with No facts involved. telephone number. client. ‘Know A7. Q7. required forand.but some banks try to avoid relationships with offshore banks.000 (other LLP. A6. in reliance on the information contained in this transactions publication or for totalling any decision based on it. Legal entities: The regulator has defined the basic form that legal entities should fill out. In what circumstances is additional due diligence required for Politically Exposed Persons (‘PEPs’)? A14. In Colombia. PricewaterhouseCoopers LLP. There are some cases which customers do not need to fill out the form e. therepresentation institution oralso exists warranty for (express or implied) is given suchastransactions to the accuracy or completeness over USD5. cashto the extent permitted transactions ofbyless law. Yes – new regulation has a risk based approach regarding AML. to the extent permitted by law. Banks should monitor changes in income or properties of their clients. what are the requirements around independent verification or authentication? A10. or refraining to act. There are regulatory requirements in relation to PEPs. Each report requires information on the origin of the money i. every international transaction should be reported to the authorities. © 2009 PricewaterhouseCoopers. USD 5. Where copies of identification documentation are provided. personal including use of the reader. Individuals should provide identification. Q16. No . The requirements surrounding independent verification or authentication vary according to each customer. what are the various thresholds in place? . In what circumstances is additional due diligence required for non face-to-face transactions and/or relationships? A17. Legal entities should provide Chamber of Commerce registration. What are the high level requirements around beneficial ownership (identification and verification)? A11. where information is available. A8. income certificate etc. You electronic not act funds upon thetransfer or information foreign contained in this currency publication exchange without obtaining transactions specific less than professional advice. its members. Are there minimum transaction thresholds. In Colombia. Q13. details of partners with shares greater than 5% and tax payments certificate. Q11. which include special additional tasks for Politically Exposed Persons (‘PEPs’). retirement fund managers and deposit accounts with a simplified process.e. this includes not only politically-related people but also publicly recognised people. The bank should perform detailed due diligence so future controls can be omitted. a PEP is defined as a publicly relevant person (not only politicians). Banks compare the copy with the original identification when the customer brings in the required documentation. multilateral organisms. In what circumstances are enhanced customer due diligence measures required? A13. Entities must define special procedures in order to perform KYC for non face-to-face interviews. than PricewaterhouseCoopers USD5. of the No information contained inisthis due diligence publication. In what circumstances are reduced/simplified due diligence arrangements available? A12.000 are believed to be linked). Q10. each of which is a separate and independent legal entity. responsibility or duty of care for any consequences of you or anyone else acting. The application and impact of laws can vary widely based on the specific facts involved. For correspondent banking relationships. Q15. There is no need for copies to be certified by a notary (this was a requirement previously). Q17. “PricewaterhouseCoopers” refers to the network of member firms of PricewaterhouseCoopers International Limited. What enhanced due diligence must be performed for correspondent banking relationships (cross-border banking and similar relationships)? A15. especially when the client manages public resources. Are relationships with shell banks specifically prohibited? A16. additional due diligence has to be performed. address. please find Questions anda linkAnswers: to a relevant report (if publicly available).000. Country by country comparison of high level Know Your Customer and Anti-Money Laundering information Customer due diligence Q8. Individuals: The regulator has defined the basic form each customer should fill out. What are the high level requirements for verification of customer identification information (individuals and legal entities)? A9. Q12. when twoemployees and or more agents do not accept or assume any liability. more than USD5. and does not constitute professional advice. Reduced requirements apply to persons or companies that operate with significant cash amounts as a result of the business they are in. Your Customer’ quick reference guide No. This publication has been prepared for general guidance on matters of interest for the personal use of the reader.

unusual transactions. each www. Tell us what matters to you and find out more by visiting us at agents do not accept or assume any liability. Are there any de-minimis thresholds below which transactions do not need to be reported? Q21. PricewaterhouseCoopers LLP. Is there a requirement to obtain authority to proceed with a current/ongoing transaction that is identified as suspicious? A24. To whom are Suspicious Activity Reports (SARs) made? Please include a link to their website.000. A24. publication or for any decision based on it. See Q20 A21. to the extent permitted by law. although it has to be reported to the UIAF. each entity is free to develop or use their specific methodology to perform transaction monitoring. or refraining to act. You should not act upon guidance © 2009 PricewaterhouseCoopers. What was the volume of SARs made to the authorities in the most recent year? Please state the GDP for the equivalent year. and does not constitute professional advice. A20. “PricewaterhouseCoopers” refers to the network of member firms of 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. and. To whom are Suspicious Activity Reports (SARs) made? Please include a link to their website. Volume of SARs: 2010 – 7.189 million (Source: data. of the products. A25.g.www.000. No.worldbank. in 158 contained No representation countries with more in this (express thanor180.g. Q19. Q18. Information and Analysis Unit (UIAF) of Colombia .gov. tax and advisory services. domestic currencies using single year official exchange rates. Financial A18. Are there any penalties for non compliance with reporting requirements e. Does the local legislation allow transactions to be monitored outside the jurisdiction? Q25. personal use of and.g. in reliance on the information contained in this entity.co A18. What was the volume of SARs made to the authorities in the most recent year? Please state the GDP for the equivalent year. No representation or warranty (express or implied) is given as contained in this publication.000. Are there any requirements (legal or regulatory) to use automated Suspicious Transaction monitoring technology? A23.000 warranty publication or implied) or is for anyasdecision given based onorit.000. professional PwC helps care and organisations forThe any consequences application individuals of you and impact create the or laws of value anyone else varyacting. Data are in current U. PwC does do not accept or assume any liability. to each “PricewaterhouseCoopers” the information the of which isor accuracy a completeness refers to the contained in this publication separate and independent network without of member obtaining legal entity. Q24.796 SARs current (UIAF) prices): 2010 – USD288. an This publication alternative has been conversion prepared factor for general guidance on matters of interest for the personal use of the reader. Yes.189 million in a ratio of 1 SAR(Source: data. in reliance of firmsfacts on the information involved. and does not constitute professional advice. Dollar figures for GDP are converted from . A20. act uponemployees and the information agents do not contained accept in this or assume publication any obtaining without liability. Dollar figures for GDP are converted from domestic * GDP atcurrencies purchaser's using single prices year is the sum official exchange of gross rates. Q21. responsibility or duty of care for any consequences of you or anyone else acting. All rights reserved. Are there any obligations to report anything more than suspicious transactions e. in this publication without obtaining specific professional advice.com. Are there any penalties for non compliance with reporting requirements e. No. Entities monitor all transactions regardless of the entity’s jurisdiction. although it has to be reported to the UIAF. and. * 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. and doespermitted by law. responsibility specific or duty ofadvice.796 SARs (UIAF) A19.co Q19. contained . financial institutions should report individual cash transactions above USD10.uiaf. PricewaterhouseCoopers International Limited. responsibility © 2009 PricewaterhouseCoopers. Are there any de-minimis thresholds below which transactions do not need to be reported? A21. It is an alternative calculated conversion factordeductions without making is used. in reliance on the information contained in this publication or for any decision based on it. A23. . other transactions etc.pwc.worldbank. A22. Is there a requirement to obtain authority to proceed with a current/ongoing transaction that is identified as suspicious? Q24. cash transactions above a certain threshold. Are there any obligations to report anything more than suspicious transactions e.? cash transactions above USD10. each entity shall define if a suspicious transaction shall be continued or not. 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. You shouldLLP.org for every ) USD40 million of GDP. Volume of SARs: 2010(in GDP – 7. No. each entity is free to develop or use their specific methodology to perform transaction monitoring. dollars.www.uiaf. Yes. to the extent permitted by law. cash transactions above a certain threshold. itsnot members. Data are in current U.S.completeness of the information contained in this publication. The application and impact of laws can vary widely based on the specific facts involved. international wire transfers.S. for depreciation of fabricated assets or for depletion and degradation of natural resources.? Q20. All rights reserved. total monthly cash transactions above USD25. No. its members. See Q20 Q22.gov. international financial institutionswire transfers. total monthly cash transactions above USD25. Financial Information and Analysis Unit (UIAF) of Colombia . employees and to the accuracy people who are committed to delivering quality in assurance.g. tipping off? A22. Special requirements and an investigation from the regulator shall be performed at an institution that does not report required periodical AML information. It is calculated without making deductions for depreciation of fabricated assets or for depletion and degradation of natural resources. This results in a ratio of 1 SAR for every USD40 million of GDP. or refraining to act.Questions and Answers: ‘Know Your Customer’ quick reference guide Country by country comparison of high level Know Your Customer and Anti-Money Laundering information Reporting Reporting Q18. of the information firmsprofessional specific of  advice. Are there any requirements (legal or regulatory) to use automated Suspicious Transaction monitoring technology? Q23. canlooking they’re widely or refraining based for. Q23. tipping off? Q22. Entities monitor all transactions regardless of the entity’s jurisdiction. Q20. You should not act upon the information is used. Special requirements and an investigation from the regulator shall be performed at an institution that does not report required periodical AML information.org * ) GDP (in current prices): * 2010results This – USD288. to the extent the reader. A19. Does the local legislation allow transactions to be monitored outside the jurisdiction? A25. Q25. 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. For a few countries where the official exchange rate does not reflect the rate effectively applied to actual foreign exchange transactions. PricewaterhouseCoopers International Limited. unusual transactions. We’re a on tospecific the network act. dollars. PricewaterhouseCoopers not constitute professional advice. each entity shall define if a suspicious transaction shall be continued or not. should report other transactions individual etc. on matters of interest only.

cimoney. ©©2009 responsible PwCIL is not responsible or 2009PricewaterhouseCoopers.CIMA Yes. O. casinos. requirements.The Theapplication applicationand andimpact impactofoflaws lawscancanvary varywidely widelybased basedon onthe thespecific specificfacts factsinvolved.ky/ext_coop_assess/eca.com. any Not liability.).rather facilitatedboth ratherthan thanaa'tick bothby 'tickbox' byway wayof ofcertain box'approach.cimoney. Each member firm is a separate legal entity and does not act as agent of PwCIL or any other member firm. thefirms member exercise firms of  of of their professional judgment or bind them in any way.not accept All rights or assume reserved.com Strathvale House. PricewaterhouseCoopers. its members.what whatare arethe thevarious variousthresholds thresholdsin inplace? place? A8. Q4. firms of the PwC network. CIMAhas whichcan hasissued canbe issuedGuidance befound foundat GuidanceNotes Noteson on Prevention Preventionand andDetection Detectionof ofMoney MoneyLaundering Launderingand at http://www. legal entity. please A7.enacted inorder enactedinto ordertotobring intolegislation legislationininSeptember bringharmonisation harmonisationwith September2008. involved.and Additionally.it.000. A6.forindividual anydecision decision based member onit.However 1996.aspx?id=180 Customer due Customer due diligence diligence Q8.pwc.repealed otherlaws lawsthat repealedthe thatcould theprevious previousAnti couldencompass encompassmoney AntiMoney MoneyLaundering LaunderingLaw moneylaundering. to the extent permitted by law.(b) regulator(s)website website (b)Other Otherfinancial financialServices. Isthere Is thereany anypractical practicalguidance locallegislation? guidanceprovided legislation?Please Pleaseinclude providedto includelink linkto tofirms firmsby towebsite. or liable for the International PricewaterhouseCoopers PricewaterhouseCoopers liable rightsfor Allrights acts or All omissions Limited.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. (e. A1. in reliance on PricewaterhouseCoopers the information International contained Limited in this (PwCIL).pwc. 90 North Church Street January 2013 January 2013 Tel: +1345 Tel: +1345 914 914 8610 8610 George Town. PwCIL does not provide any services publication or any based on to clients. as the agents do not accept or assume any liability. PricewaterhouseCoopers LLP. Thecountry The countrywas wassubject subjectto toan anIMF IMFinspection inspectionin in2009: 2009: http://www. employees and ©agents 2013 do PwC. reserved. Arethere Are thereminimum minimumtransaction transactionthresholds. or.(c) (c)Non Nonfinancial financialsector sector(e.). memberor refraining firms of to act.aspx?id=180 http://www. Law (the Additionally.. yes.bolland@ky. reader.and anddoes doesnot notconstitute constituteprofessional professionaladvice.Law. Q6. advice. A2. and. its members. andasasaaresult resultof ofthe theintroduction introductionofofthe theProceeds Proceedsof ofCrime CrimeLaw.cimoney.com Email: charles. Q7.g. Q3. the acts“PricewaterhouseCoopers” reserved. The Design Group 21383 (01/13) . to the extent permitted by law.should exemptionsfor shouldbe beadopted.ky/ext_coop_assess/eca.com. Whoisisthe Who theregulator etc. advice. Isaarisk Is riskbased basedapproach approachapproved approvedby bythe thelocal localregulator(s)? regulator(s)? A6. available). products. Box Box 258 258 Last updated: Last updated: Email: charles. withall allother 2008. amended. and. Yes--one-off Yes one-offtransactions transactionsof ofless lessthan thanKYD15. PricewaterhouseCoopers LLP. Banking. available. No member firm is  firm’s professional judgment or bind another member firm or PwCIL in any way. Theregulator The regulatorfor forAML AMLcontrols controlsisisthe theCayman CaymanIslands IslandsMonetary MonetaryAuthority Authority(“CIMA”) (“CIMA”) Q4.Please regulatorfor Pleaseinclude forAML includelink AMLcontrols linkto tothe controlsfor: for:(a) theregulator(s) (a)Banking. Grand Cayman Cayman Islands Cayman Islands KY1-1104 KY1-1104 General General Q1.where authoritiesregarding whereavailable. certainexemptions approach. Yes.No Norepresentation representationororwarranty warranty(express (express contained or implied) is given as to the accuracy or completeness of the information contained in this publication. regardingAML AMLrequirements.ky/AML_CFT/aml_cft.high highvalue valuegoods goods etc.You Youshould shouldnot notact actupon uponthe theinformation information This containedininthis thispublication publicationwithout withoutobtaining obtainingspecific specificprofessional professionaladvice. Grand Cayman George Town.bolland@ky. responsibility or duty of care for any consequences of you or anyone else acting. Thispublication publicationhashasbeen beenprepared preparedfor forgeneral generalguidance guidanceon onmatters mattersofofinterest interestfor forthe thepersonal personaluse useofofthe thereader.and andexplanation explanationwithin withinthe theGuidance Guidance Notes Q7.com.aspx?id=144 http://www.beyond beyondthe theFATF FATFrecommendations recommendationsand and local A4. Yes. A3. employees and or implied) is given as to the accuracy or completeness of the information contained in this publication. O. A8. A5. Hasthe Has thecountry pleasefind countrybeen findaalink beenthe linkto thesubject subjectof toaarelevant ofaaFATF relevantreport report(if FATF(or(orFATF-style) (ifpublicly FATF-style)Mutual publiclyavailable). bypublic publicauthorities website. Services. Q1. Q2.under underwhich whichcustomer customerdue duediligence diligenceisisnot notrequired? required? IfIfYes. Q5. Inwhat In whatyear yeardid didthe therelevant relevantAML AMLlaws lawsand andregulations regulationsbecome becomeeffective? effective? A1. N/A N/A Q3. Isthere Is thereaarequirement requirementto toretrospectively retrospectivelyverify verifythe theidentity identityof ofcustomers customersbefore beforethe thedate datethe thenew newAML AMLregime regimewas wasintroduced? introduced? A5. MutualEvaluation Evaluationor orIMF IMFassessment assessmentexercise exercisein inthe thelast lastthree threeyears? years?IfIfyes. Yes--aarisk Yes riskbased Notesthat basedapproach thataarisk approachisisfacilitated riskbased. Q8. IfIfthe theAML AMLlaws lawsand/or and/orregulations regulationsbecame becameeffective effectivein inthe thelast last22years.aspx?id=144 andTerrorist TerroristFinancing Financing(‘the (‘the“Guidance “GuidanceNotes”) Notes”) which Q5. of any each each or omissions of any of its member “PricewaterhouseCoopers” other member ofofwhich which firm nor can isisaaseparate separate and and referstotofirms refers it control thethe independent independent nor can itofcontrol thenetwork network exercise ofof member member another legalentity. particularproducts.casinos. A3.Questions and Answers: ‘Know Your Customer’ quick reference guide Country by country comparison of high level Know Your Customer and Anti-Money Laundering information Cayman Islands Cayman Islands Key contact: Key contact: Charles Charles Bolland Bolland Postal address: Postal address: P. International Limited.what whatwere werethe therequirements requirementsof ofthe theprevious previousAML AMLregime? regime? A2. 1996.g. laundering. Conduct’)in Law. in reliance on the information contained in this publication context orfor requires. based. Howeverthe (the‘Proceeds ‘Proceedsof theProceeds Proceedsof ofCriminal ofCrime CriminalConduct’) CrimeLaw. A7. or refraining to act. years. .cimoney.ky/AML_CFT/aml_cft. P. Q2.000. A4. KYD15. thresholds. “PwC” of you refers or to anyone the else network ofacting. forparticular adopted. 90 North Church Street Strathvale House. for further responsibility distribution or duty without of the care for any permission consequences of PwC. Yes Yes Q6.com.

verification of residential address (driving licence or utility bill etc. effectively covering mutual fund investments if the funds can only be returned to the beneficial owner from which they came. under which customer due diligence is not required? If Yes. Local guidance requires senior management approval. 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.000. Local guidance includes information on enhanced due diligence for Politically Exposed Persons ('PEPs'). register of members. © 2009 PricewaterhouseCoopers. Q14. A6. its directors and beneficial owners of 10% or more of the company's holdings. 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. Are there minimum transaction thresholds. Questions and Answers: Q7. Q13. . Where copies of identification documentation are provided.com. its members. What enhanced due diligence must be performed for correspondent banking relationships (cross-border banking and similar relationships)? A15. In what circumstances are enhanced customer due diligence measures required? A13. and. employees and agents do not accept or assume any liability. Documents must be originals. Note that certain entities are exempt. authorised signatory lists. What contained in this are the publication high without level specific obtaining requirements foradvice. source of of source of wealth. such as not for profit associations (including charities). in reliance on the information contained in this A9.aspx?id=180 Customer and Anti-Money Laundering information Customer due diligence Q8. financial statements etc. notary publics or civil servants.  Corporates: must identify the company. This publication has been prepared for general guidance on matters of interest for the personal use of the reader. are required on acceptance of new business. Q12. accountants. PricewaterhouseCoopers LLP. Individuals: publication or for certified any decision based funds and understanding on it. Yes . In what circumstances is additional due diligence required for Politically Exposed Persons (‘PEPs’)? A14. and explanation within the Guidance Notes that a risk based. Certificate of Incorporation. should be adopted. Company items such as Memorandum and Articles of Association. Further. Further clarification on correspondent banking relationships with shell banks is provided in the Money Laundering Guidance Notes. In what circumstances are reduced/simplified due diligence arrangements available? A12. 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). ‘Know Your Customer’ quick reference guide please find a link to a relevant report (if publicly available). No enhanced due diligence measures required for regulated correspondent banking relationships (see also response to Q16 below). Q15. b) regulated financial institutions in certain jurisdictions listed in Schedule III of the Regulations. or refraining to act. professional verification of customer The application and impactidentification of laws can varyinformation widely based on(individuals andinvolved. for example governmental bodies and pension funds for professional associations.cimoney. “PricewaterhouseCoopers” refers to the network of member firms of PricewaterhouseCoopers International Limited.). such as those listed on a recognised stock exchange. photo identification (usually passport). 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. . Q11. Beneficial owners below 10% should be identified if the entity appears structured to avoid this requirement. Examples of suitable certifiers are lawyers. rather than a 'tick box' approach. the specific facts legal entities)? No representation or warranty (express or implied) is given as to the accuracy or completeness of the information contained in this publication. reasonable measures to establish source of wealth and funds and enhanced ongoing monitoring. to the extent permitted by law. directors and officers. You should not act upon the information Q9. notarised or certified copies. d) listed institutions on certain specified exchanges and their subsidiaries (evidence must be provided for use of exemption). Key exemptions include: a) non paying accounts. Q16.ky/ext_coop_assess/eca. Are relationships with shell banks specifically prohibited? A16. high risk countries or other higher risk businesses. All beneficial owners of 10% or greater of a company's holdings must be identified/verified. All rights reserved. Yes .one-off transactions of less than KYD15. 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. by Country Thecountry country was subject to anof comparison IMF inspection high in 2009:Your level Know http://www. and e) certain other bodies. What are the high level requirements around beneficial ownership (identification and verification)? A11.a risk based approach is facilitated both by way of certain exemptions for particular products. Reduced /simplified due diligence requirements exist for the following scenarios. what are the requirements around independent verification or authentication? A10. Q10. A7. what are the various thresholds in place? A8. responsibility or duty of care for any consequences of you or anyone else acting. and does not constitute professional advice. each of which is a separate and independent legal entity.

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).

Questions and Answers:
Q14. In what circumstances is additional due diligence required for Politically Exposed Persons (‘PEPs’)?
‘Know
A14.
Your Customer’ quick reference guide
Local guidance requires senior management approval, reasonable measures to establish source of wealth and funds and enhanced
ongoing monitoring.
Country by country comparison of high level Know Your Customer and Anti-Money Laundering information

Q15. What enhanced due diligence must be performed for correspondent banking relationships (cross-border banking and similar relationships)?

A15. No enhanced due diligence measures required for regulated correspondent banking relationships (see also response to Q16 below).

Q16. Are relationships with shell banks specifically prohibited?

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.
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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

A17. In response
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Reporting

Q18. To whom are Suspicious Activity Reports (SARs) made? Please include a link to their website.

A18. The Money Laundering Regulations require that Suspicious Activity Reports are made to the Financial Reporting Authority (the “FRA”):
http://www.fra.gov.ky

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. Volume of SARs:

2011 – 406 SARs (FRA)

GDP data is not available for this specific period.

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. 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.

Q21. Are there any de-minimis thresholds below which transactions do not need to be reported?

A21. See above response to question 8 on the KYD15,000 exemption.

Q22. Are there any penalties for non compliance with reporting requirements e.g. tipping off?

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.

Q23. Are there any requirements (legal or regulatory) to use automated Suspicious Transaction monitoring technology?

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.

Q24. Is there a requirement to obtain authority to proceed with a current/ongoing transaction that is identified as suspicious?

A21. See above response to question 8 on the KYD15,000 exemption.

Q22. Are there any penalties for non compliance with reporting requirements e.g. tipping off?
Questions and Answers:
‘Know
A22. Your Customer’ quick reference guide
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.
Country by country comparison of high level Know Your Customer and Anti-Money Laundering information

Q23. Are there any requirements (legal or regulatory) to use automated Suspicious Transaction monitoring technology?

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.

Q24. Is there a requirement to obtain authority to proceed with a current/ongoing transaction that is identified as suspicious?

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 General’s direction and a resulting freeze
order. In that case, direction would be required from the AG (Attorney General) prior to proceeding with the transaction.

.
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
Q25. Does
contained in this the local
publication withoutlegislation allow
obtaining specific transactions
professional advice.to
Thebeapplication
monitored outside
and impact thecan
of laws jurisdiction?
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
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 for any decision based on it.
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
PricewaterhouseCoopers International Limited, each of which is a separate and independent legal entity.
of
procedures when such transactions occur in countries with equivalent legislation as the Cayman Islands (also known as Schedule 3

countries).

PwC helps organisations and individuals create the value they’re looking for. We’re a network of firms in 158 countries with more than 180,000
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.
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
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 for any decision based on it.

Questions and Answers:
‘Know Your Customer’ quick reference guide
Country by country comparison of high level Know Your Customer and Anti-Money Laundering information

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

Q1. In what year did the relevant AML laws and regulations become effective?

A1. Proceeds of Crime (Money Laundering) and Terrorist Financing Act (PCMLTFA) was passed in 2000, and amended 2001, 2006, 2008 and
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. 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 Canada’s AML/ATF regime in line with FATF
Recommendations.

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. In 2001, the Financial Transactions Reports Analysis Centre of Canada (“FINTRAC”) was established under the PCMLTFA to serve as
Canada’s 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

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.

.
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.
agents do notAll rightsor
accept reserved.
assume Not
anyfor furtherresponsibility
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of care for any of PwC. “PwC”of
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or refraining to act, in reliance on the International Limited (PwCIL),
information contained in this or, as the
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
© 2009 PricewaterhouseCoopers.
responsible All rights reserved.
or liable for the acts or omissions “PricewaterhouseCoopers”
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network
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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
Questions and Answers:
OSFI since FINTRAC fully relies on OSFI to conduct AML/AFT compliance initiatives.
http://www.fintrac.gc.ca/

‘Know Your Customer’ quick reference guide
http://www.iiroc.ca/Pages/default.aspx
http://www.osfi-bsif.gc.ca/osfi/index_e.aspx?ArticleID=3

Country by country comparison of high level Know Your Customer and Anti-Money Laundering information

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. 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
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
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 for any decision based on it.
© 2009 PricewaterhouseCoopers. All rights reserved. “PricewaterhouseCoopers” refers to the network of member firms of
Q5. Is there a requirement to retrospectively verify the identity of customers before the
PricewaterhouseCoopers International Limited, each of which is a separate and independent legal entity. 
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.

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

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.

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. FATF released its third evaluation of Canada in February 2008:
http://www.fatf-gafi.org/dataoecd/5/3/40323928.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. 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).

Q9. What are the high level requirements for verification of customer identification information (individuals and legal entities)?

A9. Individuals: Reporting Entities must obtain, verify and maintain the following records of an individual’s identity: customer name, date of
birth, address, the nature of the customer’s 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 corporation’s existence can be in paper or electronic format. If the record is an electronic version, firms must keep a record of
the corporation’s 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 corporation’s 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.

.
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
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 for any decision based on it.
© 2009 PricewaterhouseCoopers. All rights reserved. “PricewaterhouseCoopers” refers to the network of member firms of

Questions and Answers:
‘Know Your Customer’ quick reference guide
Country by country comparison of high level Know Your Customer and Anti-Money Laundering information

Q10. Where copies of identification documentation are provided, what are the requirements around independent verification or authentication?

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
customer’s 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.

Q11. What are the high level requirements around beneficial ownership (identification and verification)?

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 entity’s
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.

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

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.

Q14. In what circumstances is additional due diligence required for Politically Exposed Persons (‘PEPs’)?

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.

Q15. What enhanced due diligence must be performed for correspondent banking relationships (cross-border banking and similar relationships)?

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.

.
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
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or multiple transactions in a 24 hour time period by or on behalf of the same individual or entity.worldbank. PricewaterhouseCoopers LLP.Questions and Answers: ‘Know Your Customer’ quick reference guide Country by country comparison of high level Know Your Customer and Anti-Money Laundering information Q16. to the extent permitted by law.ca/publications/typologies/2012-04-eng.fintrac. Q20. address. a terrorist group. its members.ca/intro-eng. other transactions etc. or multiple transactions over a 24 hour time period. In addition. * 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. and other reports were received by FINTRAC. b) Combination of two of the following methods: referring to an independent identification product or. with the individual’s permission.pdf GDP (in current prices): Sum of GDP for 2007-2011 inclusive – USD7. confirming that a cheque drawn on a deposit account with a financial entity (other than one that is exempt from identification requirements) has cleared. Yes. all reporting entities must report the following transactions to FINTRAC. or refraining to act. This requirement applies to financial entities.000 or more in the course of a single transaction. and does not constitute professional advice. .S. unusual transactions. telephone number and date of birth record. This publication has been prepared for general guidance on matters of interest for the personal use of the reader.g. No representation or warranty (express or implied) is given as to the accuracy or completeness of the information contained in this publication. 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.org* ) This results in a ratio of 1 STR for every USD56. b) Electronic Funds Transfers – international ingoing and outgoing EFTs valued at CAD10. 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. EFTRs. employees and agents do not accept or assume any liability. in reliance on the information contained in this publication or for any decision based on it. Data are in current U. Under the PCMLTFA. Are there any obligations to report anything more than suspicious transactions e.000 or more in the course of a single transaction. You should not act upon the information contained in this publication without obtaining specific professional advice.586) of those reports were STRs (FINTRAC Typologies and Trends Reports – April 2012) http://www. “PricewaterhouseCoopers” refers to the network of member firms of PricewaterhouseCoopers International Limited. 407.835 STRs. MSBs (Money Service Business) and casinos.? A20. What was the volume of SARs made to the authorities in the most recent year? Please state the GDP for the equivalent year. and confirming that the individual has a deposit account with a financial entity (other than one that is exempt from identification requirements).2 million of GDP.asp Q19.gc.000 or more in the course of a single transaction. or over the course of multiple transactions in a 24 hour time period. In what circumstances is additional due diligence required for non face-to-face transactions and/or relationships? A17. Are relationships with shell banks specifically prohibited? A16. Thirty-three percent (approximately 134. cash transactions above a certain threshold. responsibility or duty of care for any consequences of you or anyone else acting. and d) Casino Disbursements – a casino must file a report when it makes a disbursement valued at CAD10. Q17.412 million (Source: data. international wire transfers. Dollar figures for GDP are converted from domestic currencies using single year official exchange rates. All rights reserved. or listed person (nil reports must also be filed monthly either to FINTRAC or their principal regulator such as OSFI or IIROC). LCTRs. unless stated otherwise: a) Large Cash Transactions – receipt of an amount of CAD10. Reporting Q18. each of which is a separate and independent legal entity. dollars. Yes. It is calculated without making deductions for depreciation of fabricated assets or for depletion and degradation of natural resources. A19. For a few countries where the official exchange rate does not reflect the rate effectively applied to actual foreign exchange transactions.557. A18. Recent amendments have introduced a broader and more flexible set of identification requirements related to non-face-to-face transactions.gc. Suspicious transaction reports (STRs) are filed with FINTRAC: http://www. The application and impact of laws can vary widely based on the specific facts involved. referring to a credit file. obtaining an attestation concerning an identification document for the individual from a Commissioner of Oaths or a guarantor. To whom are Suspicious Activity Reports (SARs) made? Please include a link to their website. and.fintrac-canafe. © 2009 PricewaterhouseCoopers. Volume of SARs: Between 2007 and 2011.  . 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). an alternative conversion factor is used.

A24. each any liability. MSBs (Money Service Business) and casinos. unusual transactions.asp Are there any penalties for non compliance with reporting requirements e. A22. Yes. tipping off? Q22.000 that is identifiedoras more in the course of a single suspicious? Q24. with the individual’s ‘Know Your Customer’ quick reference guide permission.000.gc. 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. EFTRs.gc. The application and impact of laws can vary widely based on the specific facts involved.g. that the transactions are related to money laundering or terrorist financing (this includes attempted suspicious transactions). Questions and Answers: b) Combination of two of the following methods: referring to an independent identification product or. international wire transfers. employees You should not actand upon agents do not accept or assume any liability. Volume of SARs: FINTRAC2007 Between mayanddisclose 2011. s.835 to law enforcement STRs. its members.S. to you You and find should not out act more by visiting upon the us at information www. outside the jurisdiction? A25. No. and does not constitute professional advice. and d) Casino Disbursements – a casino must file a report when it makes a disbursement valued at CAD10.000 and/or 5 years*imprisonment. However. law. 50 of the Regulations allows for exceptions toSuspicious reporting Large Cash Transactions (>$10. You should not act upon the information contained in this publication without obtaining specific professional advice. All rights reserved. address. “Serious” or “Very Serious”.000 and CAD500.586) of or future those compliance.pwc.org ) d) Failure to provide assistance or provide information during compliance examination: up to CAD500. unless stated otherwise: a) Large Cash Transactions – receipt of an amount of CAD10. PwC helps organisations and individuals create the value they’re looking for.ca/publications/typologies/2012-04-eng. referring to a credit file. CAD1 million for subsequent GDP (in current prices):offences. telephone number and date of birth record. and confirming that the individual has a deposit account with a financial entity (other than one that is exempt from identification requirements). to the extent permitted by law. a terrorist group.pdf b) Failure to report a large cash transaction or an electronic funds transfer: up to CAD500. responsibility or duty the information of care for contained anypublication in this consequences of you without or anyone obtaining else acting. 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. in reliance on the information contained . Yes. Data are in current U.000) for include businesses To whom are Q18. or multiple transactions in a 24 hour time period by or on behalf of the same individual or entity.fintrac. when were and other reports there received is extensive non-compliance by FINTRAC. This publication has been prepared for general guidance on matters of interest for the personal use of the reader. Q20. We’re a network of firms in 158 countries with more than 180. No representation or warranty (express or implied) is given as to the accuracy or completeness of the information contained in this publication. with the intent to prejudice a criminal investigation: up to 2 years imprisonment. legal offirms you or  of anyone else acting.com. or refraining to act. In what circumstances is additional due diligence required for non face-to-face transactions and/or relationships? A17. * 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. tax and of the reader.412 keeping requirements:million up to (Source: CAD500. transaction. . responsibility or duty refers “PricewaterhouseCoopers” in thisofpublication which is a or for anyand separate of caretofor decision theany based on independent consequences network of member it. in a ratio of 1 STR for every USD56. Dollar figures for GDP are converted from domestic currencies using single year official exchange rates. LCTRs. or littlepercent Thirty-three expectation of (approximately immediate 134. 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. advice. other transactions etc.toNoact. 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. entity.000 people who This publication has been prepared for general guidance on are committed matters to delivering of interest quality use for the personal in assurance. specific or refraining professional advice.557. all reporting entities must report the following transactions to FINTRAC. System A18. data.000 respectively. in reliance onorthe representation information warranty contained (express in thisis given as or implied) publication or for any decision based on it. All suspicious transactions and attempted suspicious transactions need to be reported.? Q23. Are there any obligations to report anything more than suspicious transactions e. 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. No representation or warranty (express or implied) is given as to the accuracy or completeness of the information This publication has been contained prepared forin this publication. each of which is a separate and independent legal entity. and. to the accuracy or completeness of the information contained in this publication.000 and/or 5 years This resultsimprisonment. or listed person (nil reports must also be filed monthly either to FINTRAC or their principal regulator such as OSFI or IIROC). CAD100. Both Q19. and. There are criminal or administrative penalties associated with non-compliance with reporting requirements. Sum of c) GDP Failure to meet record for 2007-2011 inclusive – USD7. PwC does do not accept or assume PricewaterhouseCoopers International Limited. constitute Tell us what matters professional advice. Are there any requirements (legal or regulatory) to use automated Suspicious Transaction monitoring technology? A20. Under the PCMLTFA. In A23. For a few countries where the official exchange rate does not reflect the rate effectively applied to actual foreign exchange transactions. PricewaterhouseCoopers LLP. ontomatters the extent permitted of interest byand only. to the extent permitted by law. or disclosing the contents of such a report. “PricewaterhouseCoopers” refers to the network of member firms of PricewaterhouseCoopers International Limited. Are there any de-minimis thresholds below which transactions do not need to be reported? Reporting A21.g. The application and impact of laws can vary widely based on the specific facts involved. obtaining an attestation concerning an identification document for the individual from a Commissioner of Oaths or a guarantor. contained in this publication without obtaining specific professional advice. employees and agents do not accept or assume any liability. or refraining to act. including tipping off. general guidance and. No.does PricewaterhouseCoopers LLP. cash transactions above a certain threshold. in reliance on the information contained in this publication or for any decision based on it. Q17. dollars. an alternative conversion factor is used.000 or more in the course of a single transaction. e) Disclosing the fact that a suspicious transaction report was made. Country by country comparison of high level Know Your Customer and Anti-Money Laundering information Q21.cases of non-compliance 407.000 or more in the course of Q25. A19. and advisory does not services. legislation allowortransactions over the course to beof multiple transactions monitored in a 24 hour time period. This requirement applies to financial entities.fintrac-canafe. non-compliance. © 2009 PricewaterhouseCoopers. AMPs violations are classified by the PCMLTF Regulations as “Minor”. its not constitute professional members.  . and carry maximum penalties of CAD1. Industry Classification Activity Reports (SARs) made? Please a linkinto industries identified in certain sectors of the North American their website. All rights reserved. confirming that a cheque drawn on a deposit account with a financial entity (other than one that is exempt from identification requirements) has cleared. responsibility or duty of care for any consequences of you or anyone else acting. It is calculated without making deductions for depreciation of fabricated assets or for depletion and degradation of natural resources. all reporting entities are required to report to FINTRAC transactions for which they have reasonable grounds to suspect No. http://www. © 2009 PricewaterhouseCoopers. Recent amendments have introduced a broader and more flexible set of identification requirements related to non-face-to-face transactions. Does the a single local transaction.2 million of GDP.worldbank. or multiple transactions over a 24 hour time period. Suspicious transaction reports (STRs) are filed with FINTRAC: http://www.000 for the first offence.ca/intro-eng. Regulations do not specify from/to where transactions must be monitored. addition.

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 professional advice. Q7. No. 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. organizations. reserved. . responsibility responsibility or or duty duty of care care for any anyisconsequences of of you you or anyone else acting. Q4. N/A. “PricewaterhouseCoopers” Limited. Q7. practice. member firms permitted PricewaterhouseCoopers of PricewaterhouseCoopers law.gov. Q2. advice. Eachofmember forfirm consequences a separate legal entityorand anyone doeselse acting. where where available. Only Only drug drug trafficking. 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. weapons weapons smuggling. policies.fazenda. 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. memberof member firms firms of  firm’s professional judgment or bind another member firm or PwCIL in any way.fazenda. Please Please include include link link to to the the regulator(s) regulator(s) website website A3. smuggling. customers. Nr. to Not foror accuracy completeness orfurther of of the distribution completeness information without the contained the permission information contained of in in this PwC. Limitedemployees members. 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. anyfirms liability.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. No No representation representation or or warranty warranty (express (express or © implied) or 2013 PwC. to clients. services. etc. this“PwC” refersand. casinos. beneficiaries. PricewaterhouseCoopers.gov.barbosa. 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.br/ https://www.fazenda. its PricewaterhouseCoopersInternationalits members. activities. or or refraining to to act. (iii) (iii) set set clear-cut clear-cut criteria criteria for for staff staff selection selection and and monitoring. terrorism.coaf. All PricewaterhouseCoopers The Design Group 21383 (01/13) PricewaterhouseCoopers All rights International International Limited. publication. Q3. years.g. expanding expanding its its impact. of any other member firm nor can it control rights reserved. N/A. not act refraining as agent of PwCIL act. or. kidnapping. Yes Yes https://www. COAF COAF –– Conselho Conselho de de Controle Controle das das Atividades Atividades Financeiras Financeiras –https://www. to the the extent to network of permitted extent by by law. 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. crimes crimes committed committed by by criminal criminal organizations. what what were were the the requirements requirements of of the the previous previous AML AML regime? regime? Q2. 2012. A6. No member firm is liable responsible ©© 2009 or liable for the acts or omissions 2009 PricewaterhouseCoopers.com // São Paulo. advice. website.g. LLP. available).fazenda. (b) (b) Other Other financial financial Services.br/ –https://www.sneyers@br. monitoring. (e. impact. among among other other issues.). implied) is is given as as to All rights given the the accuracy reserved. and and does does not not constitute constitute professional professional advice. please please find find aa link link to to aa relevant relevant report report (if (if publicly publicly available).teixeira@br.gov. institution. No.683 of of July July 9. Branca. 12.pwc. individual member of the PwC network.gov. Is Is aa risk risk based based approach approach approved approved by by the the local local regulator(s)? regulator(s)? Q6. 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.sneyers@br.pwc.barbosa. (ii) (ii) arrange arrange for for timely timely collection collection of of information information onon customers. kidnapping. 9. activities. entity. and and (v) (v) provide provide for for full full in-house in-house disclosure disclosure of of such such policies. casinos.coaf. 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. (iv) (iv) order order the the prior prior review review of of new new banking banking products products and and services. high high value value goods goods Q3. listed. LLP.pwc. available. (PEP). A4.pwc. Brazil Jose.teixeira@br.coaf. A6. (PwCIL). and and (ii) (ii) identifying identifying aa customer’s customer’s status status as as “politically “politically exposed exposed person” person” (PEP). 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.coaf. A2. Who Who is is the the regulator regulator for for AML AML controls controls for: for: (a) (a) Banking.and employees as the and agents agents dodo not not accept accept or or assume assume any liability. publication. A1. 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. trafficking.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.). Banking. A5. account. yes. 2012. A2.461 3.com Jose. The The new new law law expands expands the the range range of of illicit illicit A1.br/ A3. 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.613) amended amended 20022002 byby Law Law No.com alfredo. etc. . Brazil São Paulo. information contained PwCIL does this any services not provide publication publication or for any or for is any decision based on it. local local legislation? legislation? Please Please include include link link to to website. involved. January January 2013 2013 Email: Email: alfredo. terrorism. 1998 1998 (Law (Law 9. or any reliance other memberthefirm. Also.613) 9.Questions and Answers: ‘Know Your Customer’ quick reference guide Country by country comparison of high level Know Your Customer and Anti-Money Laundering information Brazil Key Key contact: contact: Alfredo Alfredo Sneyers Sneyers and and José José Postal Postal address: address: Last Last updated: updated: Barbosa Teixeira Barbosa Teixeira Centro Centro Empresarial Empresarial Agua Agua Branca. A5. in in reliance on on the information contained in in this context requires. (c) (c) Non Non financial financial sector sector (e.br/ A4. Yes Yes -. PwCIL notdecision based responsible or on it. No.. 3. requirements. Q5. the the Circular Circular Nr. beyond beyond the the FATF FATF recommendations recommendations and and Q4. issues. Services. Q6. Also. to the and. 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.683 12.com Tel: Tel: +55 +55 (0) (0) 11 11 3674 3674 3686 3686 General General Q1.

institutions member firms of located abroad. What are the high level requirements for verification of customer identification information (individuals and legal entities)? A9. documents containing the same information required for individuals who qualify and authorise the representatives to use the account. depending on the severity of the offense: (a) warning. PricewaterhouseCoopers LLP. the personal as a response use of the reader. (c) temporary prohibition from holding a senior management office in financial institutions. e) actions suspected of financing terrorist activity. PricewaterhouseCoopers LLP. A7.542 (“Letter Circular No. in a manner yet to be detailed by the Central Bank. or duty which of care for anysets forth that consequences (a) orfinancial of you institutions anyone else shall not acting. On March 12. or “COAF”). existing relationships. its members. The Central Bank may mete out the following penalties on non-compliant financial institutions and on their senior management. 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. . Q9. d) transactions apparently intended to sidestep identification mechanisms or controls. address. please find a link to a relevant report (if publicly available). 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. at a minimum. You Financial should Action not act upon Task the information contained in this publication Force withoutThe (FATF). b) actual or proposed cash transactions exceeding R$ 100 thousand. Customer due diligence Q8. information on customers. what are the various thresholds in place? A8. Circular No.e.584. date and place of birth. The application and impact of laws can vary widely based on the specific facts involved. What are the high level requirements around beneficial ownership (identification and verification)? A11. the information/documentation specified for both individuals and legal entities. No representation or warranty (express or implied) is given as to the accuracy or completeness of the information contained in this publication.fatf- gafi. 2012. under which customer due diligence is not required? If Yes. and (ii) identifying a customer’s status as “politically exposed person” (PEP). Your Customer’ quick reference guide Is a risk based approach approved by the local regulator(s)? A6. b) International PricewaterhouseCoopers enactment to agencies All rights reserved. Identification (type. what are the requirements around independent verification or authentication? A10. For insurance entities. each of which refers of establishing a separate Brazilian to the thatlegal and independent financial network of theentity. and. they also have to provide the original documents so that the institution can certify that those copies are valid. which increases the list of examples of transactions and situations which may characterize evidence of occurrence of money laundering. of Circular Limited. and does nottoconstitute the recommendations of the professional advice. (iii) set clear-cut criteria for staff selection and monitoring. Corporations: full name. and (d) cancellation of authorization or license to operate. employees and agents do not accept or assume any liability. to the extent permitted by law. (iv) order the prior review of new banking products and services. 3. Are there minimum transaction thresholds. The application and impact of laws can vary widely based on the specific facts involved. or refraining initiate to act. and subsidiaries “PricewaterhouseCoopers” No. or without economic reasons. those involving suspicious parties or values. anyonrelationship in reliance the informationwith clients. Q11. and shortly thereafter: http://www. c) suspected transactions above R$10 thousand (i. Individuals: full name. number of inscription on the Cadastro de Pessoa Física ('CPF') etc. Conselho de Controle de Atividades Financeiras (COAF). Suspected activities include. contained in thisor proceed publication or for any decision based onwith it. etc. The FATF publishes a executive summary of the mutual evaluation report which summarises the anti-money laundering (AML)/combating the financing of terrorism (CFT) measures in place in the Federative Republic of Brazil (hereinafter Brazil) as of the time of the on-site visit (26 October to 7 November 2009). responsibility or duty of care for any consequences of you or anyone else acting. number.). nationality. This publication has been prepared for general guidance on matters of interest for the personal use of the reader. date of emission and emitting institution). When clients provide copies of identification documentation. Where copies of identification documentation are provided. employees and agents do not accept a) enactment or assume ofresponsibility any liability. among others: a) actual or proposed issuance or recharge of one or more stored value cards totaling R$ 100 thousand in a given calendar month. among other issues. to the extent permitted by law. the identification information required for beneficial ownership (not required to go up to level of ultimate beneficial owners) should contain. No representation or warranty (express include: or implied) is given as to the accuracy or completeness of the information contained in this publication. and c) enactment of Letter 17 Circular No.542”). or refraining to act. tending to improve the communication between financial institutions and the Council of Control of Financial Activities (Conselho de Controle de Atividades Financeiras. Further. Suspected activities or transactions must be reported to the Brazilian financial intelligence unit. .583. 3. 3. and b) internal controls must comprise prior measures aimed at (i) confirming record data of customers and end beneficiaries. There is no information in the regulations or guidance on third party certification. by No. and does not constitute professional advice.org/topics/mutualevaluations/documents/mutualevaluationreportofbrazil. Country country comparison of high level Know Your Customer and Anti-Money Laundering information Q7.461. and (b) anti-money laundering procedures are also applicable © 2009 PricewaterhouseCoopers.. number of inscription on the Cadastro Nacional de Pessoa Jurídica ('CNPJ') etc. in reliance on the information contained in this publication or for any decision based on it. You should not act upon the information contained in this publication without obtaining specific professional advice. Q10. obtaining main specific professional measures advice. its members. address. type and date of constitution. Full name is to be verified against a local identification document.html . and (v) provide for full in-house disclosure of such policies. Names of legal entities are verified against the Register of Certification (there are also other detailed requirements). 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. if it is not possible to fully identify such clients. Questions and Answers: ‘Know Q6. and.is3. 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. (b) fine.

The same information is required for all clients. which increases the list of examples of transactions and situations which may characterize evidence of occurrence of money laundering.gov. Q16. its members. 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. None stated in local regulations or guidance. . In what circumstances is additional due diligence required for non face-to-face transactions and/or relationships? A17. if it is not possible to fully identify such clients. or “COAF”). in reliance transactions on the abovein athis information contained certain publication or for any decision based on it. and c) enactment of Letter 17 Circular No.542 (“Letter Circular No. This publication has been prepared for general guidance on matters of interest for the personal use of the reader. responsibility duty of caremore for anythan suspicious consequences of youtransactions e. The main measures include: a) enactment of Circular No. and (b) anti-money laundering procedures are also applicable to agencies and subsidiaries of Brazilian financial institutions located abroad. Volume of SARs: . No representation or warranty (express or implied) is given as to the accuracy or completeness of the information contained in this publication. All kind of suspicious activities must be reported to COAF. as follows: a) AML prevention policies must (i) specify the responsibilities at each level of the institution. In what circumstances are reduced/simplified due diligence arrangements available? A12. among other issues. What was the volume of SARs made to the authorities in the most recent year? Please state the GDP for the equivalent year. to the extent permitted by law. None stated in local regulations or guidance. each of which is a separate and independent legal entity.  A20. and (ii) identifying a customer’s status as “politically exposed person” (PEP). which sets forth that (a) financial institutions shall not initiate any relationship with clients. and b) internal controls must comprise prior measures aimed at (i) confirming record data of customers and end beneficiaries.583. Are relationships with shell banks specifically prohibited? A16. or refraining cash to act. other transactions etc.Questions and Answers: ‘Know Your Customer’ quick reference guide Country by country comparison of high level Know Your Customer and Anti-Money Laundering information Q12. in accordance with the requirements of the Central Bank. 3. All rights reserved.? © 2009 PricewaterhouseCoopers. 3. 3.461 from Brazilian Central Bank detailed how financial institutions should put these “policies” and “internal controls” into practice.fazenda. tending to improve the communication between financial institutions and the Council of Control of Financial Activities (Conselho de Controle de Atividades Financeiras.542”).g. COAF – Conselho de Controle de Atividades Financeiras – www. and (v) provide for full in-house disclosure of such policies. A18. and does not constitute professional advice. Yes. Q15. To whom are Suspicious Activity Reports (SARs) made? Please include a link to their website. and. they are closely monitored.br Q19. (ii) arrange for timely collection of information on customers. PricewaterhouseCoopers LLP. In what circumstances is additional due diligence required for Politically Exposed Persons (‘PEPs’)? A14. The application and impact of laws can vary widely based on the specific facts involved.584. threshold. international wire transfers. Q17. Q14. transactions. Approximately 1 million SARs per year for the last 2 years.coaf. In what circumstances are enhanced customer due diligence measures required? A13. No . “PricewaterhouseCoopers” refers to the network of member firms of PricewaterhouseCoopers International Limited. A19. employees and Q20. or proceed with existing relationships. unusual or anyone else acting. b) enactment of Circular No. 3. (iv) order the prior review of new banking products and services. You should not act upon the information contained in this publication without obtaining specific professional advice. What enhanced due diligence must be performed for correspondent banking relationships (cross-border banking and similar relationships)? A15. Q13. Circular 3. Reporting Q18.although they are not prohibited. Are there agents do not accept any any or assume obligations to reportoranything liability. (iii) set clear-cut criteria for staff selection and monitoring.

responsibility or duty of care for any consequences of you or anyone else acting. to the extent permitted by law. tax and of member advisory firms of  services. Q24. .000 people“PricewaterhouseCoopers” © 2009 PricewaterhouseCoopers. No representation or warranty (express or implied) is given as to the accuracy or completeness of the information contained in this publication. No.g. and does not constitute professional advice.g. Yes . employees and agents do not accept or assume any liability. for activities below BRL5. its members.000). or refraining to act. You should not act upon the information contained in this publication without obtaining specific professional advice. PwC does do not accept or assume any liability. . Are there any requirements (legal or regulatory) to use automated Suspicious Transaction monitoring technology? A23. other transactions etc. or refraining to act. We’re a network of firms in 158 countries with more than 180.the area of Supervision of the Central Bank of Brazil reviews and monitors compliance with very closely.pwc. The application and impact of laws can vary widely based on the specific facts involved. Are there any penalties for non compliance with reporting requirements e. PricewaterhouseCoopers LLP. www. in reliance on the information contained in this publication or for any decision based on it. Your Customer’ quick reference guide Volume of SARs: Approximately Country by 1 million SARsof country comparison perhigh year level for theKnow last 2 years. tipping off? A22. and. This publication has been prepared for general guidance on matters of interest for the personal use of the reader.? A20. who are committed to delivering quality refers to in assurance. Are there any obligations to report anything more than suspicious transactions e. Your Customer and Anti-Money Laundering information Q20. and. Does the local legislation allow transactions to be monitored outside the jurisdiction? A25. In this case all monitoring between the COAF and the Bank is documented.com. No representation or warranty (express or implied) is given as to the accuracy or completeness of the information contained in this publication. The bank secrecy law prevents a client's activities being monitored or reported outside the country. Q21. 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. You should not act upon the information contained in this publication without obtaining specific professional advice. international wire transfers. All kind of suspicious activities must be reported to COAF.Questions and Answers: ‘Know A19. PricewaterhouseCoopers International Limited. and does not constitute professional advice. Q23. responsibility or duty of care for any consequences of you or anyone else acting. Are there any de-minimis thresholds below which transactions do not need to be reported? A21. Tell us what matters to you and find out more by visiting us at This publication has been prepared for general guidance on matters of interest only. Yes in some cases. PwC helps organisations and individuals create the value they’re looking for. to the extent permitted by law. in reliance on the information contained in this publication or for any decision based on it. Q25. Yes. unusual transactions. Is there a requirement to obtain authority to proceed with a current/ongoing transaction that is identified as suspicious? A24. Q22. cash transactions above a certain threshold. All rights reserved. the network each of which is a separate and independent legal entity. Yes.000 (approx USD3.

Yes . Tel: +591 2-240 8181 La Paz. This publication has been prepared for general guidance on matters of interest for the personal use of the reader. 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.Unidad de Investigaciones Financieras). the PwC network. Their methodology used to determine whether a risk based approach is used or not. please find a link to a relevant report (if publicly available). do notAllaccept rights or reserved. 1997. No member firm is © 2009 PricewaterhouseCoopers.llanos@bo. Hansa Piso 19.pwc. Q3. its members. member firms of PricewaterhouseCoopers or refraining to act. Customers who engage in transactions above this limit must provide information relating to the transaction to the regulatory body (UIF .mercado@bo. each of which is a separate and independent legal entity. Is there a requirement to retrospectively verify the identity of customers before the date the new AML regime was introduced? A5. For the Financial Sector. Mcal. In what year did the relevant AML laws and regulations become effective? A1. as the context requires.pwc. Is there any practical guidance provided to firms by public authorities regarding AML requirements. Each member firm is a separate legal entity and does not act as agent of PwCIL or any other member firm. information contained in this or.com / Ed. No.gob. Santa Cruz.all transactions below USD10. Q5. A7. high value goods etc.bo/ Q4. 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.asfi. Is a risk based approach approved by the local regulator(s)? A6. and. what were the requirements of the previous AML regime? A2. and does not constitute professional advice. The application and impact of laws can vary widely based on the specific facts involved. PricewaterhouseCoopers LLP. casinos. Are there minimum transaction thresholds. is their responsibility. where available.). Q6. . Q7. under which customer due diligence is not required? If Yes.com Av. to the extent permitted by law. beyond the FATF recommendations and local legislation? Please include link to website. No. the Financial System Authority (ASFI) is responsible for analysing suspicious financial activities: https://www. A3. in reliance on theInternational Limited (PwCIL). If the AML laws and/or regulations became effective in the last 2 years. Yes – the Financial System Authority (ASFI) provides guidance for external auditors to perform the AML review. . publication or forindividual member any decision basedfirms on of it. Customer due diligence Q8. (c) Non financial sector (e. No – every financial institution is an independent organisation.000 do not require customer due diligence measures. “PwC” refers consequences of youto orthe network anyone elseofacting. No representation or warranty (express or implied) is given as to the accuracy or completeness of the information contained in this publication. Bolivia General Q1. The Design Group 21383 (01/13) network exercise of member of another firms firm’s member of  professional judgment or bind another member firm or PwCIL in any way. Please include link to the regulator(s) website. N/A. (b) Other financial Services. January 2013 vladimir. Q2.Questions and Answers: ‘Know Your Customer’ quick reference guide Country by country comparison of high level Know Your Customer and Anti-Money Laundering information Bolivia Key contact: Boris Mercado / Vladimir Llanos Postal address: Last updated: Email: boris. Who is the regulator for AML controls for: (a) Banking. You should not act upon the information contained in this publication without obtaining specific professional advice. employees and ©agents 2013 PwC. assumeNot anyfor furtherresponsibility liability. what are the various thresholds in place? A8. A4.g. PwCIL does not provide any services to clients. responsible All rights reserved. or liable for the acts or omissions “PricewaterhouseCoopers” of any other refersthe member firm nor can it control to the PricewaterhouseCoopers International Limited. distribution without or dutythe permission of care for anyof PwC.

Questions and Answers:
‘Know Your Customer’ quick reference guide
Country by country comparison of high level Know Your Customer and Anti-Money Laundering information

Q9. What are the high level requirements for verification of customer identification information (individuals and legal entities)?

A9. The law and its procedures define minimum requirements to identify customers:

Individuals: birth date, nationality, National Identification number (carné de identidad) or passport number, Número de Identificación
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, Número de Identificación Tributaria (NIT) (which is the Taxpayers Identification Number), business
address, telephone number, shareholders list, executives list, commercial references and entity constitution documents.

Q10. Where copies of identification documentation are provided, what are the requirements around independent verification or authentication?

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.

Q11. What are the high level requirements around beneficial ownership (identification and verification)?

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.

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

A12. Simplified due diligence arrangements are available for transactions below the USD10,000 threshold.

Q13. In what circumstances are enhanced customer due diligence measures required?

A13. Enhanced due diligence arrangements are required for transactions above the USD10,000 threshold.

Q14. In what circumstances is additional due diligence required for Politically Exposed Persons (‘PEPs’)?

A14. None stated in local regulations or guidance.

Q15. What enhanced due diligence must be performed for correspondent banking relationships (cross-border banking and similar relationships)?

A15. None stated in local regulations or guidance.

Q16. Are relationships with shell banks specifically prohibited?

A16. No.

Q17. In what circumstances is additional due diligence required for non face-to-face transactions and/or relationships?

A17. None stated in local regulations or guidance.

Reporting
.
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
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 for any decision based on it.
© 2009 PricewaterhouseCoopers. All rights reserved. “PricewaterhouseCoopers” refers to the network of member firms of
PricewaterhouseCoopers International Limited, each of which is a separate and independent legal entity. 

Q16. Are relationships with shell banks specifically prohibited?

A16. No.

Questions and Answers:
Q17. In what circumstances is additional due diligence required for non face-to-face transactions and/or relationships?
‘Know
A17.
Your Customer’ quick reference guide
None stated in local regulations or guidance.
Country by country comparison of high level Know Your Customer and Anti-Money Laundering information

Reporting
.
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
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
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
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 for any decision based on it.

A18. Banks and financial
© 2009 PricewaterhouseCoopers. institutions
All rights prepare periodic reports
reserved. “PricewaterhouseCoopers” refers to for the UIF
the network of (AML)
PricewaterhouseCoopers International Limited, each of which is a separate and independent legal entity.
member at the
firms of Financial System Authority: https://www.asfi.gob.bo/.

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, except for all transactions above USD10,000.

Q21. Are there any de-minimis thresholds below which transactions do not need to be reported?

A21. Yes, below USD10,000.

Q22. Are there any penalties for non compliance with reporting requirements e.g. tipping off?

A22. The regulator establishes the appropriate penalties to be charged according to the degree of non compliance.

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 regulator establishes the appropriate procedure for suspicious activities.

Q25. Does the local legislation allow transactions to be monitored outside the jurisdiction?

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.

PwC helps organisations and individuals create the value they’re looking for. We’re a network of firms in 158 countries with more than 180,000
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.
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© 2009 PricewaterhouseCoopers. All rights reserved. “PricewaterhouseCoopers” refers to the network of member firms of
PricewaterhouseCoopers International Limited, each of which is a separate and independent legal entity. 

Questions and Answers:
‘Know Your Customer’ quick reference guide
Country by country comparison of high level Know Your Customer and Anti-Money Laundering information

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

Q1. In what year did the relevant AML laws and regulations become effective?

A1. 1996.

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. UIF: Unidad de Información 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 .

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. 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 .

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 - although local regulators require certain procedures to be performed without taking into account the risk profile of the transaction or
customer.

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. Yes http://www.fatf-gafi.org/topics/mutualevaluations/documents/mutualevaluationofargentina.html

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. 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
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, 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
publication or for any decision based 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
responsible or liable for the acts or omissions
© 2009 PricewaterhouseCoopers. of any other
All rights reserved. member firm nor can it control
“PricewaterhouseCoopers” refers the exercise
to the of another
network
PricewaterhouseCoopers International Limited, each of which is a separate and independent legal entity.
The Design Group 21383 (01/13)
member
of member firms firm’s
of

professional judgment or bind another member firm or PwCIL in any way.

Questions and Answers:
‘Know Your Customer’ quick reference guide
Country by country comparison of high level Know Your Customer and Anti-Money Laundering information

Q9. What are the high level requirements for verification of customer identification information (individuals and legal entities)?

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.

Q10. Where copies of identification documentation are provided, what are the requirements around independent verification or authentication?

A10. There is no information on independent verification of documentation in local guidance. This is because original documents must be seen by
financial institutions.

Q11. What are the high level requirements around beneficial ownership (identification and verification)?

A11. The same as 'permanent' clients, therefore beneficial ownership must be identified.

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

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.

Q13. In what circumstances are enhanced customer due diligence measures required?

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).

Q14. In what circumstances is additional due diligence required for Politically Exposed Persons (‘PEPs’)?

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.

Q15. What enhanced due diligence must be performed for correspondent banking relationships (cross-border banking and similar relationships)?

A15. None stated in local regulations or guidance.

Q16. Are relationships with shell banks specifically prohibited?

A16. No.

Q17. In what circumstances is additional due diligence required for non face-to-face transactions and/or relationships?

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

Q18. To whom are Suspicious Activity Reports (SARs) made? Please include a link to their website.

A18. UIF: www.uif.gov.ar
.
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
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
PricewaterhouseCoopers
GDP for the equivalent LLP, its members,
year. employees and
Q19.
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 for any decision based on it.

A19. Volume of SARs:
© 2009 PricewaterhouseCoopers.
2011 – 11,087
PricewaterhouseCoopers
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) 
GDP (in current prices):
*

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. Volume of SARs:
2011 – 11,087 SARs (source: http://www.uif.gov.ar/uif/images/links/Informe-de-gestin-2011.pdf page 72)
Questions and Answers:
GDP (in current prices):

‘Know Your Customer’ quick reference guide
2011 – USD46,710 million (Source: data.worldbank.org* )

This
UIF: results in a ratio of 1 SAR for every USD4.2 million of GDP.
www.uif.gov.ar
A18. by country comparison of high level Know Your Customer and Anti-Money Laundering information
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.
Q19. threshold, international wire transfers, other transactions etc.?

A19. Volume of SARs:
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)

GDP (in current prices):
*
2011there
Are – USD46,710 millionthresholds
any de-minimis (Source: data.worldbank.org )
below which transactions do not need to be reported?
Q21.
This results in a ratio of 1 SAR for every USD4.2 million of GDP.
A21. ARP50,000 (approximately USD10,000).

Q20. Are there any obligations to report anything more than suspicious transactions e.g. unusual transactions, cash transactions above a certain
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.

Q21. Are there any de-minimis thresholds below which transactions do not need to be reported?
Q23. Are there any requirements (legal or regulatory) to use automated Suspicious Transaction monitoring technology?

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.

Q24. Is there a requirement to obtain authority to proceed with a current/ongoing transaction that is identified as suspicious?

A24. No.

Q25. Does the local legislation allow transactions to be monitored outside the jurisdiction?

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
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
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
alternative conversion factor is used.
.
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
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 for any decision based on it.
© 2009 PricewaterhouseCoopers. All rights reserved. “PricewaterhouseCoopers” refers to the network of member firms of
PricewaterhouseCoopers International Limited, each of which is a separate and independent legal entity. 
*
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
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
alternative conversion factor is used.
.
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
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 for any decision based on it. PwC helps organisations and individuals create the value they’re looking for. We’re a network of firms in 158 countries with more than 180,000
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
© 2009 PricewaterhouseCoopers. All rights reserved. “PricewaterhouseCoopers” refers to the network of member firms of
www.pwc.com.
PricewaterhouseCoopers International Limited, each of which is a separate and independent legal entity. 
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
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 for any decision based on it.

gov. N/A. If the AML laws and/or regulations became effective in the last 2 years. “PwC” refers to the network of member firms of PricewaterhouseCoopers International Limited (PwCIL). high value goods etc. Ho Chi Minh City. Customer due diligence Q8. Not for further distribution without the permission of PwC.ingrid. Saigon Tower. Each member firm is a separate legal entity and does not act as agent of PwCIL or any other member firm.gov. It is the first time regulations on anti-money laundering have been issued in the form of a law. The assessment body ‘APG’ performed an assessment in 2009 . No member firm is © 2009 PricewaterhouseCoopers.http://www. Are there minimum transaction thresholds. No. All rights reserved. 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.org/documents/default. beyond the FATF recommendations and local legislation? Please include link to website.pwc. what were the requirements of the previous AML regime? A2.com 4th Floor.). or. 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.perschmann@vn. However the SBV has issued guidance to credit institutions in relation to the installation and use of TRAML programme: http://www. individual member firms of the PwC network. 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. or liable for the acts or omissions “PricewaterhouseCoopers” of any other refers the member firm nor can it control to the network exercise PricewaterhouseCoopers International Limited.apgml. Q6. Is there any practical guidance provided to firms by public authorities regarding AML requirements.vn Q4.sbv. The Law on anti-money laundering however requests clients’ information must be updated regularly. . 07/2012/QH13 issued in 2012 (effective on 1 January 2013) Q2.aspx?DocumentCategoryID=17 . Q3.g. (c) Non financial sector (e. as the context requires. 1519 District 1.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 Anti-Money Laundering Laundering information information Vietnam Key contact: Annett Perschmann-Taubert Postal address: Last updated: Email: annett. Vietnam General Q1. please find a link to a relevant report (if publicly available). The Design Group 21383 (01/13) of member of another firms of member  firm’s professional judgment or bind another member firm or PwCIL in any way. No. casinos. Criminal Law issued in 1999 (effective on 1 July 2000) Law No. Anti-Money Laundering Information Centre under the State Bank of Vietnam (SBV): http://www. In what year did the relevant AML laws and regulations become effective? A1. (b) Other financial Services. Q7. Yes.vn Q5. A4. A7. under which customer due diligence is not required? If Yes.sbv. where available. Is there a requirement to retrospectively verify the identity of customers before the date the new AML regime was introduced? A5. responsible All rights reserved. Is a risk based approach approved by the local regulator(s)? A6. Please include link to the regulator(s) website A3. Who is the regulator for AML controls for: (a) Banking. each of which is a separate and independent legal entity. what are the various thresholds in place? © 2013 PwC. PwCIL does not provide any services to clients. 29 Le Duan Street January 2013 Tel: +84 (8) 3823 0796 ext.

Q15. Q10. phone number. date of birth. nationality. and does not constitute professional advice. All rights reserved. such as transfer of land use rights. “PricewaterhouseCoopers” refers to the network of member firms of c) International PricewaterhouseCoopers OrganisationsLimited.org/documents/default. In what circumstances are reduced/simplified due diligence arrangements available? A12. what are the requirements around independent verification or authentication? A10. please find to a relevant report (if publicly available). date and place of issue and permanent/current address b) For individual foreign clients: full name. sale and management of properties is provided. date and place of issue. For corporate clients. In what circumstances is enhanced customer due diligence measures required? A13. occupation. d) Notaries. such as e. ‘Know A7. What enhanced due diligence must be performed for correspondent banking relationships (cross-border banking and similar relationships)? . Q12. This publication has been prepared for general guidance on matters of interest for the personal use of the reader. Q14. Country by country comparison of high level Know Your Customer and Anti-Money Laundering information Questions and Answers: Customer due diligence ‘Know Your Customer’ quick reference guide Q8. Q9. occupation. d) Information regarding beneficiary. address of head office. if they act on their customers behalf to make transactions. if they carry out certain transactions. Q11. 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. phone number. e) Organisations providing trust services if they carry out certain transactions. 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. passport number. IfbyYes. Yes. Where copies of identification documentation are provided. position. 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. Under Article 9. In case of corporate beneficiary: information regarding ownership and control rights. Article 11 of the Law on anti-money laundering allows engagement of other organisations to conduct the verification. No representation or warranty (express . Country Are there minimum transaction thresholds. In what circumstances is additional due diligence required for Politically Exposed Persons (‘PEPs’)? A14. information on the founder and representatives. Certain non-financial institutions are required to identify customers: a) Casino/gaming businesses.g. identity card number or passport number. Article 9 of the Law on anti-money laundering stipulates that the clients’ information must include: a) For individual Vietnamese clients: full name. areas of operations and business. © 2009 PricewaterhouseCoopers. date of birth. None stated in local regulations or guidance. nationality. Q13. 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.apgml. accounting and legal services companies. or management of customer’s bank accounts. Your Customer’ quick reference guide The assessment body ‘APG’ performed an assessment in 2009 . None stated in local regulations or guidance. make suspicious transactions or if there is any doubt regarding the client’s identification information. b) Real estate management or property services companies. c) For corporate clients: full and abbreviated trading name. trading in precious each of which metals is a separate and gemstones and independent  legal entity. What are the high level requirements for verification of customer identification information (individuals and legal entities)? A9. it is required to verify the beneficial ownership and apply necessary measures in order to know and update information of beneficial ownership.http://www.if they carry out transactions in relation to purchase/sale of precious metals/gemstones with large value of cash. Financial institutions must verify clients’ information in certain circumstances such as: when clients open accounts. position. such as providing services such as establishment of companies. visa.2 of the Law on anti-money laundering. overseas/Vietnam address. What are the high level requirements around beneficial ownership (identification and verification)? A11. make transactions of high value. 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.aspx?DocumentCategoryID=17 . Questions Q7. fax number. if brokerage services in relation to purchase. A6.

based on the specific facts involved. 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. Are there any penalties for non compliance with reporting requirements e. No. in reliance on the information contained in this publication or for any decision based on it.g. values below the stipulated values as set out in A20. To whom are Suspicious Activity Reports (SARs) made? Please include a link to their website. Under the Law on anti-money laundering.and Anti-Money Laundering information Country by country comparison of high level Know Your Customer and Anti-Money Laundering information Q15. The application and impact of laws can vary widely based on the specific facts involved. the following transactions should be reported: a) high value transactions (level of value to be stipulated by the Prime Minister). In what circumstances is additional due diligence required for non face-to-face transactions and/or relationships? A17. Q22. Yes. PricewaterhouseCoopers LLP. to the extent permitted by law.? A20.  A16. PricewaterhouseCoopers LLP. . its members. cash transactions above a certain threshold. Q16. Not specifically mentioned in the regulations. In what circumstances is additional due diligence required for Politically Exposed Persons (‘PEPs’)? ‘Know Questions A14. This publication has been prepared for general guidance on matters of interest for the personal use of the reader.gov. Q21. All rights shell banks specifically prohibited? “PricewaterhouseCoopers” refers to the network of member firms of PricewaterhouseCoopers International Limited.  . No representation or warranty (express or implied) is given as to the accuracy or completeness of the information contained in this publication. to the extent permitted by law. No representation or warranty (express or implied) is given as to the accuracy or completeness of the information contained in this publication. c) individuals bring currency/gemstones/valuable papers exceeding the threshold stated by the SBV. d) In case the partner bank’s clients can make payment through the partner bank’s accounts opened at the institutions. Are there any requirements (legal or regulatory) to use automated Suspicious Transaction monitoring technology? A23. “PricewaterhouseCoopers” refers to the network of member firms of PricewaterhouseCoopers International Limited. and. Questions and Answers: Q14. Reporting Q18. 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 ‘Know Your Customer’ quick reference guide andcountry Country by to enhance monitoring business comparison of highrelationship/transactions level Know Your Customerwith clients. responsibility or duty of care for any consequences of you or anyone else acting. Are there any obligations to report anything more than suspicious transactions e.sbv. employees and agents do not accept or assume any liability. Q23. Q17. b) electronic money transfer with value exceeding the threshold stated by the SBV. penalties for administrative violations. each of which is a separate and independent legal entity. 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 application and as required impact by vary of laws can thewidely institutions.g. However the Law on anti-money laundering refers in Article 17 to business through “introduction” by a third party. What enhanced due diligence must be performed for correspondent banking relationships (cross-border banking and similar relationships)? A15. such as transactions with high value or transactions with individuals in countries or territories included in the list published by FATF. A13. and identification. in reliance on the information contained in this publication or for any decision based on it. and. international wire transfers. © 2009 PricewaterhouseCoopers. State Bank of Vietnam: http://www. and does not constitute professional advice. the . A19. or refraining to act. unusual transactions. 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. other transactions etc. None stated in local regulations or guidance. b) Assessing the implementation of measures on prevention of money laundering of the partner bank. All rights reserved. responsibility or duty of care for any consequences of you or anyone else acting. What was the volume of SARs made to the authorities in the most recent year? Please state the GDP for the equivalent year. Are there any de-minimis thresholds below which transactions do not need to be reported? A21. with reserved. Not mentioned in the regulations. You should not act upon the information contained in this publication without obtaining specific professional advice. employees and agents do not accept or assume any liability. the partner bank's reputation and ensure the partner bank must be subject to supervision and management of the foreign competent management agencies. A18. each of which is a separate and independent legal entity. in addition to suspicious transactions. Information on the volume of SARs is not publicly available. tipping off? A22. Are relationships © 2009 PricewaterhouseCoopers. its members. Yes. The Law on anti-money laundering however requires the reporting entity to exercise special supervision of certain transactions. or refraining to act. Q20. c) Must be approved by the General Director (Director) or authorisation persons before setting up the banking agent relations.vn/wps/portal/vn Q19.

and does not constitute professional advice. responsibility or duty of care for any consequences of you or anyone else acting. c) individuals bring currency/gemstones/valuable papers exceeding the threshold stated by the SBV. Are there any penalties for non compliance with reporting requirements e. . agents do not accept or assume any liability. Q22. Country by country comparison of high level Know Your Customer and Anti-Money Laundering information . Is there a requirement to obtain authority to proceed with a current/ongoing transaction that is identified as suspicious? This publication has been prepared for general guidance on matters of interest for the personal use of the reader. penalties for administrative violations. Questions and Answers: Q23. Your Customer’ quick reference guide No. and does not constitute professional advice. PwC does do not accept or assume any liability. Your Customer’ quick reference guide Are there any de-minimis thresholds below which transactions do not need to be reported? A21. or refraining to act. All rights reserved.g. No. PwC helps organisations and individuals create the value they’re looking for. Under the Law on anti-money laundering. The Law on anti-money laundering requests the related institutions to delay the suspicious transaction and reports immediately to the or implied) is given as to the accuracy or completeness of the information contained in this publication. each transactions of which toand is a separate beindependent monitoredlegal outside entity. such as transactions with high value or transactions with individuals in countries or territories included in the list published by FATF. A20. responsibility or duty of care for any consequences of you or anyone else acting. No representation or warranty (express A24. Does theInternational PricewaterhouseCoopers local legislation allow Limited. tipping off? A22. We’re a network of firms in 158 countries with more than 180. tax and advisory services. You should not act upon the information contained in this publication without obtaining specific professional advice. Yes. in addition to suspicious transactions. No. This publication has been prepared for general guidance on matters of interest only. © 2009 PricewaterhouseCoopers. PricewaterhouseCoopers LLP. by country comparison of high level Know Your Customer and Anti-Money Laundering information Country Yes. its members. Are there any requirements (legal or regulatory) to use automated Suspicious Transaction monitoring technology? ‘Know A23. Questions and Answers: ‘Know Q21.com. in reliance on the information contained in this publication or for any decision based on it. the following transactions should be reported: a) high value transactions (level of value to be stipulated by the Prime Minister). in reliance on the information contained in this publication or for any decision based on it. the jurisdiction?  A25.Q24. Tell us what matters to you and find out more by visiting us at www.pwc. The Law on anti-money laundering however requires the reporting entity to exercise special supervision of certain transactions. to the extent permitted by law. and.000 people who are committed to delivering quality in assurance. “PricewaterhouseCoopers” refers to the network of member firms of Q25. to the extent permitted by law. You should not act upon the information contained in this publication without obtaining specific professional advice. and. values below the stipulated values as set out in A20. No representation or warranty (express or implied) is given as to the accuracy or completeness of the information contained in this publication. or refraining to act. employees and authorities. The application and impact of laws can vary widely based on the specific facts involved. b) electronic money transfer with value exceeding the threshold stated by the SBV.

what are the various thresholds in place? © 2013 PwC.amlo. Who is the regulator for AML controls for: (a) Banking. All rights reserved.pdf Q5. The Anti-Money Laundering Office (the “AMLO”). A4. Is there a requirement to retrospectively verify the identity of customers before the date the new AML regime was introduced? A5.imf.pwc. http://www.amlo. . casinos.pdf. No. http://www. No member firm is © 2009 PricewaterhouseCoopers.org/documents/docs/17/Thailand%20DAR. beyond the FATF recommendations and local legislation? Please include link to website.go.pdf. Not for further distribution without the permission of PwC.go.. (b) Other financial Services.e. http://www. Yes.Questions and Questions andAnswers: 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 Anti-Money Laundering Laundering information information Thailand Key contact: Vorapong Sutanont Postal address: Last updated: Email: vorapong. under which customer due diligence is not required? If Yes. 1999. Q7.com 15th Floor. responsible All rights reserved. If the AML laws and/or regulations became effective in the last 2 years.apgml. Each member firm is a separate legal entity and does not act as agent of PwCIL or any other member firm. individual member firms of the PwC network. January 2013 Tel: +66 2344 1429 179/74-80 South Sathorn Road. Thailand General Q1. Yes.th Q4. Q2. please refer to the following website.go. high value goods etc. The Design Group 21383 (01/13) of member of another firms firm’s member of  professional judgment or bind another member firm or PwCIL in any way.)? Please include link to the regulator(s) website A3. A7. where available.th/amlofarm/farm/en/files/MR_1(1). or. Is a risk based approach approved by the local regulator(s)? A6. Bangkok 10120.pdf and http://www. as the context requires.g.pdf and http://www.th/amlofarm/farm/en/files/MR_2(2). or liable for the acts or omissions “PricewaterhouseCoopers” of any other refersthe member firm nor can it control to the network exercise PricewaterhouseCoopers International Limited. Are there minimum transaction thresholds. Q3. please refer to the last report issued since 24 July 2007 at the following website. In what year did the relevant AML laws and regulations become effective? A1. Q6. http://www. please find a link to a relevant report (if publicly available). PwCIL does not provide any services to clients. Customer due diligence Q8. “PwC” refers to the network of member firms of PricewaterhouseCoopers International Limited (PwCIL). 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.th/amlofarm/farm/en/files/DAR_thai. No. what were the requirements of the previous AML regime? A2. 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. each of which is a separate and independent legal entity. N/A. i.amlo. (c) Non financial sector (e. Is there any practical guidance provided to firms by public authorities regarding AML requirements.go. please refer to the following website.org/external/np/pp/eng/2011/051111.amlo. Bangkok City Tower.sutanont@th.

2555 (2012).. [Refer to Ministerial Regulation No.5/2533]. what are the various thresholds in place? due diligence Customer is not required? and Anti-Money Laundering information A8. to the extent permitted by law. Q10. please find a link to a relevant report (if publicly available). You should not act upon the information contained in this publication without obtaining specific professional advice. Where copies of identification documentation are provided. etc. 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. (2) the director authorized to conduct a transaction on behalf of the juristic person or legal arrangement. princess of Thailand. identity card. © 2009 PricewaterhouseCoopers. What are the high level requirements around beneficial ownership (identification and verification)? A11. Institutions should verify and maintain the power of attorney of beneficial owners from the customer who is conducting the transaction. Using an alias is not permitted. automotive hire-purchase entity.e. In general. PricewaterhouseCoopers businessesInternational money “PricewaterhouseCoopers” All rights reserved. of member firms of  jewellery and gold shops. employees and . regardless of the transaction.pdf. by Country Arecountry there minimum transaction comparison ofthresholds.org/documents/docs/17/Thailand%20DAR. Covered entities: Under Know Your Customer guidance: Banks (including state-owned banks).pdf and http://www. exchanges and remitters. where copies of identification documents are provided. 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. 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. finance companies. Financial Institution: In line with Know Your Customer guidance. government. Where foreign documents are provided.th/amlofarm/farm/en/files/DAR_thai. What are the high level requirements for verification of customer identification information (individuals and legal entities)? A9. The application and impact of laws can vary widely based on the specific facts involved. certification by a public notary and authentication by the embassy of the country that the document is originally issued. Q9. Any transaction made by the following parties including king. In what circumstances is enhanced customer due diligence measures required? . Individuals: Institutions should verify the original identification documents. please refer to the last report issued since 24 July 2007 at the following website. PricewaterhouseCoopers LLP. Limited.org/external/np/pp/eng/2011/051111. what are the requirements around independent verification or authentication? A10.E. 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. may be required. the sources of high value transactions or unusual characteristics or those that are not related to the business of the customers. Country by country comparison of high level Know Your Customer and Anti-Money Laundering information Questions and Answers: ‘Know Your Customer’ quick reference guide Customer due diligence Q8. 2553 and Ministerial Regulation Prescribing Rules and Procedures for Customer Due Diligence B. public organisation or other government agencies.amlo. good faith and without gross negligence. No representation or warranty (express or implied) is given as to the accuracy or completeness of the information contained in this publication. The institution should maintain copies of verified identification documents for a period of five years. Your Customer’ quick reference guide No. state-owned enterprise. The verification shall be completed with professional care. prince.go. This publication has been prepared for general guidance on matters of interest for the personal use of the reader. and deposit/lending cooperatives and traders that are not financial institutions engaging in business involving the operation of.pdf. insurance companies. queen. each or car dealers. household registration book. may be reduced or exempted as the Minister deems fit.imf. passport. 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. real-estate refers toasset separate and independent antique management the network legalshops. Legal entities: Institutions should obtain company registration documents as well as examining the type of business. electronic payment businesses. 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. securities dealers.apgml.. its members. of which is aagents/brokers. Q13. Q12. http://www. personal loan businesses.E. Q11. Questions and Answers: ‘Know A7. high levelunder Knowwhich customer Your If Yes. http://www. companies. foundation.E. In what circumstances are reduced/simplified due diligence arrangements available? A12. Q7. such copies shall normally be verified as true and correct by the owner of the document and/or by verification against the original. 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. electronic card and credit-card businesses. full name and other document details. and does not constitute professional advice. i. 2555 (2012) effective from 22 August 2012). and.

All rights reserved. responsibility or duty of care for any consequences of you or anyone else acting. public organisation or other government agencies. foundation.amlo. Q17. Questions and Answers: Q12. terrorism have not been implemented or applied. You should not act upon the information contained in this publication without obtaining specific professional advice. any illegal transactions or transactions with an unreasonable purpose require enhanced due diligence. . The application and impact of laws can vary widely based on the specific facts involved. What enhanced due diligence must be performed for correspondent banking relationships (cross-border banking and similar relationships)? A15. laundering or refraining to act. A11. Limited. the institution should enhance ongoing customer due diligence if transactions are suspected to be money laundering related. In addition. Reporting Q18. or is a person or member of a group of persons who was . To whom are Suspicious Activity Reports (SARs) made? Please include a link to their website. Any transactions made by PEPs require additional due diligence.resides exposed person “PricewaterhouseCoopers” in a iscountry each of which a separateorand refersin territory to a theforeign where independent network of legalthe country. comparison of high level Know Your Customer and Anti-Money Laundering information Country by country comparison of high level Know Your Customer and Anti-Money Laundering information Q13. anti-money vary widely based on the specific facts involved. No. 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. the enhanced customer due diligence required if.go. Per recent Ministerial Regulation Prescribing Rules and Procedures for Customer Due Diligence B. order The application under the law andon impact of laws can laundering. in reliance on the information contained in this publication or for any decision based on it. its members. prince. Your and Customer’ quick reference guide Answers: Any transaction made by the following parties including king. 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. may be reduced or exempted as the Minister deems fit. In what circumstances is additional due diligence required for non face-to-face transactions and/or relationships? A17. No representation or warranty (express or implied) is given as to the accuracy or completeness of the information contained in this publication. “PricewaterhouseCoopers” refers to the network of member firms of PricewaterhouseCoopers International Limited. etc. a predicate offense or money laundering offense. b) prepared This publication has been the customer for generalisguidance or wasonamatters person whosefortransaction of interest the personal usewas restrained. Q14. to the extent permitted by law. princess of Thailand. Enhanced customer due diligence measures are required when the transaction is complex.E. complicated and suspicious transactions. of the reader. member firms of  international standards for anti-money laundering and counter financing of entity. PricewaterhouseCoopers LLP. state-owned enterprise. Institutions should establish appropriate policies and procedures that include guidance for correspondent banks by enhancing procedures and paying special attention to high value. 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. e) International the customer is a politically All rights reserved. identified as having an involvement in money laundering or terrorism under the law of another country. Institutions should verify and maintain the power of attorney of beneficial owners from the customer who is conducting the transaction. Q15. In what circumstances is enhanced customer due diligence measures required? A13. Are relationships with shell banks specifically prohibited? A16. This publication has been prepared for general guidance on matters of interest for the personal use of the reader. A18. government. employees and agents do not accept or assume any liability. its members.  . and. and h) the customer is designated by notification of the Secretary-General. unusually large. PricewaterhouseCoopers d) the customer © 2009 PricewaterhouseCoopers. The Director of AMLO http://www.or Youfrozen. No representation or warranty (express or implied) is given as to the accuracy or completeness of the information contained in this publication. and does not constitute professional advice. inoffense reliance onorthe associated with a person information contained in this who committed publication or for any decision based on it. or act should not whose assets upon the were information contained in this publication vested without obtaining to the specific professional state by a court advice. [Refer to ‘Know Your Customer’ quick reference guide Ministerial Country by country Regulation No. each of which is a separate and independent legal entity. and. Q16.th/ Q19. and for any customer suspected to be linked with a money laundering offence or terrorism. and or whose does assets not constitute were seized professional advice. PricewaterhouseCoopers LLP. 2555 (2012). to the extent permitted by law.5/2533]. What was the volume of SARs made to the authorities in the most recent year? Please state the GDP for the equivalent year. © 2009 PricewaterhouseCoopers. or refraining to act. 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. 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. In what circumstances are reduced/simplified due diligence arrangements available? ‘Know Questions A12.. queen. responsibility a duty person who of care committed for any consequences a predicate offense of you or anyone or money else acting. employees and agents do not accept c) the any or assume customer is or was or liability. In what circumstances is additional due diligence required for Politically Exposed Persons (‘PEPs’)? A14. Furthermore.

PricewaterhouseCoopers LLP. coloured stones. to the extent permitted by law. © 2009 PricewaterhouseCoopers. gold. c) trader dealing in the business of selling or leasing of cars. its members.000: 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.S.868 of GDP. coloured stones. cash transactions above a certain threshold. or ornaments decorated with gems. Changwad Land Office. to the extent permitted by law. Q20.amlo. 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 financial institution shall have the duty to report if the transaction is equal or more than THB700. You should not act upon the information contained in this publication without obtaining specific professional advice. 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.564 SARs (AMLO) ( Noted: This is only latest information available in the AMLO thus not updated) GDP (in current prices): 2009 – USD263. For a few countries where the official exchange rate does not reflect the rate effectively applied to actual foreign exchange transactions. Customer’ quick reference guide Answers: The Director of AMLO ‘Know Your Customer’ quick reference guide http://www. in reliance on the information contained in this publication or for any decision based on it. PricewaterhouseCoopers LLP. Dollar figures for GDP are converted from domestic currencies using single year official exchange rates. All rights reserved.th/ Country by country comparison of high level Know Your Customer and Anti-Money Laundering information Country by country comparison of high level Know Your Customer and Anti-Money Laundering information Q19. 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 THB100. It is calculated without making deductions for depreciation of fabricated assets or for depletion and degradation of natural resources. its members. 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. responsibility or duty of care for any consequences of you or anyone else acting. A19. Volume of SARs: 2009 – 1. and.worldbank. e) trader dealing in the business of antiques trade under the law on Control of Sale by Auction and Antique Trade. and. dollars.org* ) . responsibility or duty of care for any consequences of you or anyone else acting.  . You should not act upon the information contained in this publication without obtaining specific professional advice.g. the financial institution shall have the duty to report if the transaction is equal or more than THB100. This publication has been prepared for general guidance on matters of interest for the personal use of the reader. The application and impact of laws can vary widely based on the specific facts involved. “PricewaterhouseCoopers” refers to the network of member firms of PricewaterhouseCoopers International Limited. Are there any penalties for non compliance with reporting requirements e. diamonds. and does not constitute professional advice. other transactions “PricewaterhouseCoopers” refers to etc. What was the volume of SARs made to the authorities in the most recent year? Please state the GDP for the equivalent year. except in the case of a transfer by succession to a statutory heir. wire transfers. To whomand Answers: are Suspicious Activity Reports (SARs) made? Please include a link to their website. Except in the case of electronic fund transferred transaction. whether or not it is the transaction under a) or b) or not. No representation or warranty (express or implied) is given as to the accuracy or completeness of the information contained in this publication.000. employees and agents do not accept or assume any liability.go. or c) a suspicious transaction. or c) being made in connection with a suspicious transaction. Reporting Questions Q18. Q21. Yes. or b) trader dealing in the business of electronic payment service under the law on the supervision of electronic payment service business. A Land Office of Bangkok Metropolitan.380. each of which is a separate and independent legal entity. or refraining to act. Data are in current U. This publication has been prepared for general guidance on matters of interest for the personal use of the reader.505 million (Source: data. and does not constitute professional advice.  A20.g. The application and impact of laws can vary widely based on the specific facts involved. d) trader dealing in the business of immovable property broker or agent. an alternative conversion factor is used. each of which is a separate and independent legal entity.000. b) a transaction connected with the property worth equal or more than THB5 million.? the network of member firms of PricewaterhouseCoopers International Limited. No representation or warranty (express or implied) is given as to the accuracy or completeness of the information contained in this publication. in reliance on the information contained in this publication or for any decision based on it. 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. Are there any de-minimis thresholds below which transactions do not need to be reported? A21. international © 2009 PricewaterhouseCoopers. This results in a ratio of 1 SAR for every USD190. see 20 above. All rights reserved. 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.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 . tipping off? * 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. Q22. diamonds. ‘Know Your Questions and A18. Except in the case of movable property involving electronic fund transfer or payments. b) trader dealing in the business of gems. gold. unusual transactions. . or refraining to act. Yes . Are there any obligations to report anything more than suspicious transactions e. employees and agents do not accept or assume any liability.

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. Yes. by law. to report extent that transaction permitted to the technology? Office whenLLP. A22. to the extent permitted by law. in reliance on the information contained in this publication or for any decision based on it. above. and does not constitute professional advice. You should not act upon the information contained in this publication without obtaining specific professional advice. This publication has been prepared for general guidance on matters of interest for the personal use of the reader. Is there a requirement to obtain authority to proceed with a current/ongoing transaction that is identified as suspicious? A24. No representation or warranty (express or implied) is given as to the accuracy or completeness of the information contained in this publication.  PwC helps organisations and individuals create the value they’re looking for.g.000 both. responsibility or duty of care for any consequences of you or anyone else acting. We’re a network of firms in 158 countries with more than 180.000: ‘Know Your Customer’ quick reference guide a) trader dealing in the business of electronic money card that is not a financial institution under the Notification of the Ministry of c) beingFinance made in connection determining with a suspicious on electronic money card transaction.000 have the duty to report through that transaction the period of violation to or the untilOffice actingwhen it appears that such in accordance. Are there Questions and Answers: any de-minimis thresholds below which transactions do not need to be reported? exchange. . gold. Q21. or refraining to act. Q24. in reliance on the information contained in this publication or for any decision based on it. All rights reserved. tax and advisory services. 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 agents do not accept or assume any liability. responsibility or duty of care for any consequences of you or anyone else acting. 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. to the extent permitted by law. coloured ‘Know Your Customer’ quick reference guide A21. an alternative conversion factor is used. see 20 above.000 people who are committed to delivering quality in assurance.com. No. 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. and.pwc. Are there any de-minimis thresholds below which transactions do not need to be reported? A21. © 2009 PricewaterhouseCoopers. coloured stones.institution tipping off? under the Notification of the Ministry of Finance determining on credit card or the law on financial institution business. a) trader dealing in the business of electronic money card that is not a financial institution under the Notification of the Ministry of A23. alternative conversion factorNotification is used. It is calculated without making deductions for depreciation of fabricated assets or for depletion and degradation of natural resources. Q22. * 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. Changwad Ministry of Finance Land Office. ofbe theliable Ministry of Finance determining on exceeding Personal Loan Businesses under Supervision or under the law orontofinancial . 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. 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. and. or refraining to act. responsibility or duty of care for any consequences of you or anyone else acting. 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. Q25. b) trader dealing in the business of gems.S. Tell us what matters to you and find out more by visiting us at www. “PricewaterhouseCoopers” refers to the network of member firms of PricewaterhouseCoopers International Limited. in reliance on the information contained in this publication or for any decision based on it. or an amountproperty of cash worth equal equal or more or more than THB5 million. It is transaction is funded by an amount of cash equal or more than THB500. or b) trader dealing in the business of electronic payment service under the law on the supervision of electronic payment service The following designated non-financial businesses and professions shall have the duty to report the transaction to the Office when it business. employees and agents do not accept or assume any liability. and does not constitute professional advice. tothe and. trader dealing in the business of selling or leasing of cars. You should not act upon the information contained in this publication without obtaining specific professional advice. . Data are in current U. The application and impact of laws can vary widely based on the specific facts involved. diamonds. © 2009 PricewaterhouseCoopers. Dollar figures for GDP are converted from domestic currencies a) single Any person using traderyeardealing who reports in the or makes official exchange business a For rates. or ornaments decorated with gems. Data are in current U. or b) trader dealing in the business of electronic payment service under the law on the supervision of electronic payment service  business. tipping off? * 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. dollars. except in the case of a transfer by succession to a than THB100. its members. PricewaterhouseCoopers it appears that its members. and does not constitute professional advice. d) trader dealing in the business of immovable property broker or agent. PricewaterhouseCoopers International determining on electronic each of which is a separatemoney card orlegal and independent the entity. All rights reserved. each of which is a separate and independent legal entity.S. or refraining to act. No representation or warranty (express or implied) is given as to the accuracy or completeness of the information contained in this publication. PricewaterhouseCoopers LLP. “PricewaterhouseCoopers” refers to the network of member firms of Finance Limited.000: calculated without making deductions for depreciation of fabricated assets or for depletion and degradation of natural resources. Dollar figures for GDP are converted from domestic currencies using single year official exchange rates. The application and impact of laws can vary widely based on the specific facts involved. or the law on financial institution business. exceeding Yes. No. PwC does do not accept or assume any liability.g. .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. gold. 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. Are there any penalties for non compliance with reporting requirements e. Yes. Does the local legislation allow transactions to be monitored outside the jurisdiction? A25. For a few countries where the official exchange rate does not reflect the rate effectively applied to actual foreign exchange transactions.000 to THB500. You should not act upon the information contained in this publication without obtaining specific professional advice. No representation or warranty (express 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. No. such and employees Q23. competent official shall to imprisonment for a term not two years or to a fine of THB50. This publication has been prepared for general guidance on matters of interest only. diamonds. or information Q22. Are there f) any traderpenalties dealingfor nonbusiness in the compliance with reporting of credit card thatrequirements is not a financial e. dollars.000 non-financial a daily finebusinesses not exceeding shallTHB5. institution business. law on financial institution business. c) see 20 stones. This publication has been prepared for general guidance on matters of interest for the personal use of the reader.

No member firm is © 2009 PricewaterhouseCoopers. which is responsible for the matters listed in Paragraph 2. Please include link to the regulator(s) website A3. Q2. if one of the following conditions is met: a) the account is opened upon request for a third party. There is no single unified rule-making. what were the requirements of the previous AML regime? A2.pdf) © 2013 PwC.tw/mlpc/notice. Ministry of Justice. d) The prosecutors and courts are responsible for the prosecution of money laundering crimes. 2008.pwc. “PwC” refers to the network of member firms of PricewaterhouseCoopers International Limited (PwCIL). A4. please find a link to a relevant report (if publicly available). (http://www. Taiwan has not been the subject of a FATF Mutual Evaluation since 2008. No . Each member firm is a separate legal entity and does not act as agent of PwCIL or any other member firm. Taiwan was the subject of the “IMF Working Paper . (b) Other financial Services.gov. In what year did the relevant AML laws and regulations become effective? A1.org/external/pubs/ft/wp/2011/wp11170.A Quantitative Assessment of Financial Conditions in Asia” dated July 2011. credit departments of farmers’ (fishermen’s) associations.mjib. (c) Non financial sector (e. customer identification and record keeping requirements.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 levelKnow KnowYour Your Customer Customerand andAnti-Money Anti-Money Laundering Laundering information information Taiwan Key contact: Eric Tsai Postal address: Last updated: Email: eric. Section 1 January 2013 Tel: +886 2 2729 6687 Taipei. Is a risk based approach approved by the local regulator(s)? A6. Q6. which serves as the financial intelligence unit of Taiwan. . 2006. financial institutions are required to re-validate a customer’s identification. b) For AML issues concerning wire transfers. The major provisions of the Money Laundering Control Act include a list of predicate offences for money laundering. Article 10 of the Money Laundering Control Act. With respect to the IMF assessment. Taiwan 110 General Q1. or. If the AML laws and/or regulations became effective in the last 2 years. N/A Q3. or c) the customer opened the account by mail. beyond the FATF recommendations and local legislation? Please include link to website. Q7. b) the financial institution becomes suspicious about the activities of the customer. supervisory and enforcement government AML body in Taiwan. In 2012. Taiwan's anti-money laundering legislation is embodied in The Money Laundering Control Act. Yes. the Central Bank of Taiwan serves as a co-rule making body along with the Financial Supervisory Commission. Is there any practical guidance provided to firms by public authorities regarding AML requirements. 333 Keelung Road.). 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. shall be changed into “Financial Supervisory Commission”. Practical guidance is provided to financial institutions. high value goods etc. 2007. is in charge of receiving and compiling money laundering reports. each of which is a separate and independent legal entity. credit cooperative associations. including banks. The website of the practical guidance is at http://www.g. Not for further distribution without the permission of PwC. after the customer has opened an account. Q4. such as: a) The Financial Supervisory Commission is in charge of adopting AML rules for financial institutions and for ongoing supervision. the Executive Yuan made a publication to announce that the “Financial Supervisory Commission of Executive Yuan”. and the creation of a financial intelligence unit. The Design Group 21383 (01/13) of of member another firms of member  firm’s professional judgment or bind another member firm or PwCIL in any way. Is there a requirement to retrospectively verify the identity of customers before the date the new AML regime was introduced? A5.htm Q5. disclosure of suspicious transactions. the Anti-Money Laundering Division. 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. A7.however. All rights reserved. individual member firms of the PwC network. casinos. responsible All rights reserved. PwCIL does not provide any services to clients. c) The Anti-Money Laundering Prevent Center of the Ministry of Justice. 1996 (amended in 2003.imf. or liable for the acts or omissions “PricewaterhouseCoopers” of any other refers the member firm nor can it control to the network exercise PricewaterhouseCoopers International Limited. Who is the regulator for AML controls for: (a) Banking. and 2009). international cooperation. Different jobs related to AML are handled by different authorities.com 27F. life insurance companies and futures brokers. securities brokers.tsai@tw. Investigation Bureau. as the context requires. where available.

among other things. what are the requirements around independent verification or authentication? A10. National Health Insurance Card. the teller should enforce proper control measures and conduct regular reviews on the account. under which customer due diligence is not required? If Yes. student identity card. it is not necessary to request the minutes of directors' meetings. Original forms of identification are necessary as photocopies are not accepted. may serve to be the non-individual account representative's (or responsible person’s) secondary identification certificates.000 (or the equivalent in foreign currency). Questions and please find Answers: a link to a relevant report (if publicly available). or based on reasonable doubts. 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. Financial institutions are required to exercise extraordinary diligence if the transaction of a customer meets.  Q8. The Minimum Transaction Threshold and the scope of the financial transaction. Are there minimum transaction thresholds. official documents or other supporting certificates and shall. The teller should. passport. if one of the following conditions is met: a) the account is opened upon request for a third party.g.org/external/pubs/ft/wp/2011/wp11170. Legal entities: Where a non-individual applies to open an account. In the case of opening an account for a company. b) the financial institution becomes suspicious about the activities of the customer. “PricewaterhouseCoopers” refers to the network of member firms of Customer due diligence PricewaterhouseCoopers International Limited. or c) the customer opened the account by mail. All rights reserved. A6. household registry book or household registry certificate. check with the Joint Credit Information Centre (‘JCIC’) or conduct an enquiry through the Bank’s own database on whether the individual is a political celebrity in other countries. Ministry of Justice. after the customer has opened an account. ‘Know A7. A5. The registration license for incorporation of the company. Q11. What are the high level requirements around beneficial ownership (identification and verification)? A11.imf. the teller shall obtain certificates verifying incorporation registration. In what circumstances are reduced/simplified due diligence arrangements available? . Taiwan was the subject of the “IMF Working Paper . with respect to the currency transactions carried out after the account is opened. if the company’s registration license has been collected and the search and recording of the company’s registration has been conducted by a financial organization. If yes. Q10. at the same time. if any.however. the customer’s identity and the transaction records to the Investigation Bureau. other than his/her identity card. securities brokers and life insurance companies. 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. what are the various thresholds in place? A8. deemed by an international AML institution. and submit the financial transaction. the financial institution is required to obtain two types of identification and to keep copies irrespective of transaction amounts. driving license. Q9. the financial institutions referred to in the Money Laundering Control Act shall ascertain the identity of customer and keep the transaction records as evidence. credit cooperative associations. the procedures for ascertaining the identity of the customer. Q12.pdf) Country by country comparison of high level Know Your Customer and Anti-Money Laundering information © 2009 PricewaterhouseCoopers. Your Customer’ quick reference guide Is a risk based approach approved by the local regulator(s)? Yes. 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. by country comparison of high level Know Your Customer and Anti-Money Laundering information Country Q7. in addition. No . Individuals: Where an individual applies to open an account. What are the high level requirements for verification of customer identification information (individuals and legal entities)? A9. Before a financial institution accepts a request of opening account. obtain the minutes of its Board of Directors meeting. Questions and Answers: ‘Know Q6. for any currency transaction exceeding a certain amount of money (the “Minimum Transaction Threshold”). obtain other document(s) which could verify his/her identity e. With respect to the IMF assessment. financial institutions are required to re-validate a customer’s identification.A Quantitative Assessment of Financial Conditions in Asia” dated July 2011. each of which is a separate and independent legal entity. (http://www. However. credit departments of farmers’ (fishermen’s) associations. For banks. the teller shall. Where copies of identification documentation are provided. Your Customer’ quick reference guide Taiwan has not been the subject of a FATF Mutual Evaluation since 2008. Articles of Incorporation or financial statements before approving the application to open an account. the Minimum Transaction Threshold is TWD500.

Questions Q11. and Anti-Money or based information Laundering on reasonable doubts.of while on matters interestverifying the de for the personal use facto needs. the case shall still be handled as required if the transaction of a same client amounts to over the specific amount. Ministry of Justice for the following transactions (even if the amount is TWD500. Q14. of the reader. 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. In such a case. 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. What areand Answers: the high level requirements around beneficial ownership (identification and verification)? ‘Know Questions A11. of Justice responsibility responds or duty on consequences of care for any the contraryofwithin ten days you or anyone from receipt else acting. PricewaterhouseCoopers LLP. © 2009 PricewaterhouseCoopers. employees and agents do not accept or assumeBureau. In what circumstances is each of which is enhanced a separate due customer and independent diligencelegal entity. andshall submit does not theprofessional constitute name to the Investigation advice. The a case-by-case and impactbasis of lawsmay be widely can vary dispensed based on with for such the specific factsaccounts involved.000. a) for any currency transaction exceeding TWD500. 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. 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. Country by country comparison of high level Know Your Customer and Anti-Money Laundering information Q12. Reporting . of to or refraining theact. No representation or warranty (express or implied) is given as to the accuracy or completeness of the information contained in this publication. financial institutions shall ascertain the identity of the customer. © 2009 PricewaterhouseCoopers. it is necessary to identify the correspondent bank has strictly identified the customer’s identity and be able to provide the relevant identity information if necessary. A10. responsibility or duty of care for any consequences of you or anyone else acting. its members. including whether it has been subject to a money laundering or terrorist financing investigation or regulatory action. c) the amounts paid by a national lottery dealer. measures required?  A13. hotel. . and. supermarket chain. clinic. All rights reserved. without obtaining Declaration specific professional on application advice. “PricewaterhouseCoopers” refers to the network of member firms of PricewaterhouseCoopers Q13. “PricewaterhouseCoopers” refers to the network of member firms of PricewaterhouseCoopers International Limited.  . Original forms of identification are necessary as photocopies are not accepted. Q15. nevertheless. guidance the Bank. category and amount of the transaction. government corporation. PricewaterhouseCoopers LLP. International Limited.on the information contained in this in reliance publication or for any decision based on it. Ministry act upon the of information contained in this publication Justice for information. banks are exempted from the requirement to report to the Investigation Bureau.name list. a public/private school or a public utility and the funds prove to comply with the laws and regulations concerned of the government. Banks are required to: a) gather sufficient information about a respondent institution to fully understand the nature of the respondent’s business and to determine. and ascertain that they are adequate and effective. each of which is a separate and independent legal entity. a duplicate copy of the payment note shall be archived to verify the transaction. transportation entity. Q17. gas station. restaurant. You should notBureau. hospital. d) document the respective AML responsibilities of each institution. 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. identity Card number (including the code which enables the search of the identity of the transaction counterpart). However. and. In what circumstances are reduced/simplified due diligence arrangements available? A12. 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. and does not constitute professional advice. its members. This publication has been prepared for general guidance on matters of interest for the personal use of the reader. Your and Customer’ quick reference guide Answers: Financial institutions are required to exercise extraordinary diligence if the transaction of a customer meets. keep the transaction records as evidence and submit the financial transaction. While customer identification verification and record-keeping are still required. e) where a correspondent relationship involves the maintenance of ‘payable–through accounts’. Q16. to the extent permitted by law. among other things. the customer’s identity and the transaction records to the Investigation Bureau and the Ministry of Justice. and e) in cases of non-individual accounts such as a department store. or refraining to act. Know Your deemed by an international Customer AML institution. to the extent permitted by law. from publicly available information. Ministry any liability. Nounless the Investigation representation or warranty (express or implied) is given as to the accuracy or completeness of the information contained in this publication. All rights reserved.g. Are relationships with shell banks specifically prohibited? A16. an entity that exercises government power (within the consigned scope).000 or larger). You should not act upon the information contained in this publication without obtaining specific professional advice. In what circumstances is additional due diligence required for non face-to-face transactions and/or relationships? A17. employees and agents do not accept or assume any liability. In what circumstances is additional due diligence required for Politically Exposed Persons (‘PEPs’)? A14. the ‘Know Your Customer’ quick reference guide 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. b) assess the respondent institution’s AML controls. 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. The application and impact of laws can vary widely based on the specific facts involved. the reputation of the institution and the quality of supervision. in reliance on the information contained in this publication or for any decision based on it. honouring a cheque issued by a fellow bank. No specific requirements are required for PEPs. What enhanced due diligence must be performed for correspondent banking relationships (cross-border banking and similar relationships)? A15. megastore. c) obtain approval from senior management before establishing new correspondent relationships.

employees and any liability. Negotiable securities with a face value exceeding a certain amount. GDP data is not available for this specific period. in reliance on the information contained in this in this publication or for any decision based on it. a) Any financial institution not reporting any currency transaction exceeding TWD500. other transactions etc. its members. in reliance on the information contained in this A18. . However.? A20.000 people who are committed to delivering quality in assurance. Are there any obligations to report anything more than suspicious transactions e. Volume of SARs: 2011 – 7. securities brokers and life insurance companies. as required by relevant laws and regulations. PwC helps organisations and individuals create the value they’re looking for. Are there any de-minimis thresholds below which transactions do not need to be reported? A21. Unit (FIU). or refraining to act. Q17. its members. cash transactions above a certain threshold. © 2009 PricewaterhouseCoopers. Q25. each of which is a separate and independent legal entity. in reliance on the information contained agents do not accept or assume any liability.000. any shell banks to use their account. the Threshold is TWD 500. Yes. or No representation You should not warranty act upon (express the information or implied) is given as contained in this publication without obtaining specific professional to the accuracy advice. No representation or warranty (express or implied) is given as to the accuracy or completeness of the information contained in this publication. b) passengers or service crew on board who cross the border with the carrier and carry the following items shall make declarations to customs. Financial publication or for any decisionIntelligence based on it.com. Yes. and does specific not constitute professional advice. to the extent permitted by law. Taiwan is a member of the Egmont Group and The Asia/Pacific Group on Money Laundering. For banks. You should not act upon This publication has been prepared for general guidance on matters the information of interest contained in thisforpublication the personal use ofobtaining without the reader. a. contained in thisTo whom are publication Suspicious without Activity obtaining specific Reports professional (SARs) advice. employees and agents do not accept or assume any liability. b) Any financial institution not reporting any suspicious transaction shall be punished by a fine between TWD200. responsibility or duty of care for any consequences of you or anyone else acting. the Anti-Money Laundering Division. unusual transactions. Q21. The customs shall report subsequently to the Investigation Bureau. tax and advisory services.g. publication or for any decision based on it. tipping off? A22.000 and TWD1 million. and does not constitute professional advice.ontothe thespecific facts involved. b. Are there any requirements (legal or regulatory) to use automated Suspicious Transaction monitoring technology? A23.514 SARs deals of suspicious transactions were reported by financial institutions to the Investigation Bureau. 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).tw/mlpc/download-1. No.  . each of which is a separate and independent legal entity. shall be punished by a fine between TWD200. based on the specific facts involved. Is there a requirement to obtain authority to proceed with a current/ongoing transaction that is identified as suspicious? A24.htm. international wire transfers. “PricewaterhouseCoopers” refers to the network of member firms of PricewaterhouseCoopers International Limited.g. Ministry of Justice: http://www.gov. credit departments of farmers’ (fishermen’s) associations. credit cooperative associations.000 (or the equivalent in foreign currency). 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. responsibility or duty of care for any consequences of you or anyone else acting. Q24. Questions Your and Customer’ quick reference guide 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. A19. This publication has been prepared for general guidance on matters of interest for the personal use of the reader. and. All rights reserved. Q23. PricewaterhouseCoopers LLP. A16. Taiwan has cooperated with some countries to investigate AML matters. responsibility or duty of care for any consequences of you or anyone else acting.  Q19. “PricewaterhouseCoopers” refers to the network of member firms of PricewaterhouseCoopers International Limited. Does the local legislation allow transactions to be monitored outside the jurisdiction? A25. to the extent permitted by law. and. and. Ministry of Justice. or refraining to act. Ministry of Justice. You should not act upon the information Q18. ‘Know Your Customer’ quick reference guide Country by country comparison of high level Know Your Customer and Anti-Money Laundering information Country by country comparison of high level Know Your Customer and Anti-Money Laundering information Reporting . or refraining to act. All rights reserved. Q20. any suspicious transaction shall be reported to vice-CEO or the same level personnel. In respect of the internal controls of a financial institution. We’re a network of firms in 158 countries with more than 180. Yes.pwc.mjib. 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”). professional advice. Investigation Bureau. Any non-suspicious currency transaction below TWD500. © 2009 PricewaterhouseCoopers. extent permitted NoPwC by law.000 dollars and TWD1 million. Are there any penalties for non compliance with reporting requirements e. Q22. Cash of foreign currency with total amount exceeding a certain amount. This publication has been prepared for general guidance on matters of interest only. made? and The application Please impactinclude a link of laws can to their vary widely website.000. What was the volume of SARs made to the authorities in the most recent year? Please state the GDP for the equivalent year. Tell us what matters to you and find out more by visiting us at www. no fine shall be imposed. In what circumstances is additional due diligence required for non face-to-face transactions and/or relationships? Questions and Answers: ‘Know A17. and does not constitute professional advice. PricewaterhouseCoopers LLP. The application or completeness and impact of the information of laws can contained vary in this widely based publication.

what are the various thresholds in place? © 2013 PwC.pdf (Consultation Paper released for designation of Q5. 2 nd follow-up report was performed in February 2011. individual member firms of the PwC network. Q6. Yes. casinos.sg/public/www/content. (b) Other financial Services. Q2. please find a link to a relevant report (if publicly available).cra.sg/en/Regulations-and- Financial-Stability/Regulatory-and-Supervisory-Framework/Anti-Money-Laundering-and-Countering-the-Financing-of-Terrorism. each of which is a separate and independent legal entity. Q7. member firm nor can it control “PricewaterhouseCoopers” refers the exercise to the of another network PricewaterhouseCoopers International Limited. Please refer to link: http://www. Q3. Not for further distribution without the permission of PwC. Please refer to link: http://www. Who is the regulator for AML controls for: (a) Banking. Yes.kwok@sg.g.mas. http://www. Each member firm is a separate legal entity and does not act as agent of PwCIL or any other member firm. “PwC” refers to the network of member firms of PricewaterhouseCoopers International Limited (PwCIL).gov. Yes. Are there minimum transaction thresholds. N/A. . In what year did the relevant AML laws and regulations become effective? A1. Please include link to the regulator(s) website A3. http://www. what were the requirements of the previous AML regime? A2.org/media/fatf/documents/reports/mer/FoR%20Singapore.Questions and Questions andAnswers: 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 Anti-Money Laundering Laundering information information Singapore Key contact: Kwok Wui San Postal address: Last updated: Email: wui.gov.aspx (c) AML is regulated by Commercial Affairs Department of Singapore.sg/~/media/resource/publications/consult_papers/2012/9%20October%202012%20Designation%20of%20Tax%20Crim es%20as%20Money%20Laundering%20Predicate%20Offences%20in%20Singapore. Is there any practical guidance provided to firms by public authorities regarding AML requirements. If the AML laws and/or regulations became effective in the last 2 years.pwc. Is there a requirement to retrospectively verify the identity of customers before the date the new AML regime was introduced? A5. (a) & (b) AML is regulated by the Monetary Authority of Singapore (“MAS”). as the context requires. FATF Mutual Evaluation undertaken in February 2008. 048424 General Q1. A7.gov.gov. high value goods etc. 1993 (amended 1999 and 2006). under which customer due diligence is not required? If Yes.aspx?sid=42 http://www.cad.pdf Customer due diligence Q8.gov. All rights reserved. or. The Design Group 21383 (01/13) member of member firms firm’s of  professional judgment or bind another member firm or PwCIL in any way.san. PwCIL does not provide any services to clients. 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. A4. 17-00 PWC Building.). January 2013 Tel: +65 (0) 6236 3087 Singapore. beyond the FATF recommendations and local legislation? Please include link to website.sg/amlcft/stro/ Q4.aspx?sc_q=finance%20companies&sc_type=Filter%20by%20category&sc_p=1 http://app.mas. Is a risk based approach approved by the local regulator(s)? A6.mas. 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.com 8 Cross Street.fatf-gafi.sg/Regulations-and-Financial-Stability/Regulatory-and-Supervisory-Framework/Anti-Money-Laundering-and- Countering-the-Financing-of-Terrorism/Notices-and- Guidelines. of any other All rights reserved. where available. (c) Non financial sector (e. No member firm is responsible or liable for the acts or omissions © 2009 PricewaterhouseCoopers.

Q7. A6. 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. Questions and Answers: ‘Know A7. business relations or transactions the financial institution assesses to present a higher risk for money laundering and terrorist financing. Are Country there minimum by country transaction comparison ofthresholds. what are the various thresholds in place? due diligence Customer is not required? and Anti-Money Laundering information A8. What are the high level requirements around beneficial ownership (identification and verification)? A11. In what circumstances are reduced/simplified due diligence arrangements available? A12. 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. what are the requirements around independent verification or authentication? A10. the financial institution needs to take reasonable measures to obtain information sufficient to identify and verify the identities of the beneficial owner (s). b) documenting the respective AML/CFT responsibilities of each bank. high levelunder Knowwhich customer Your If Yes. In all circumstances. and does not constitute professional advice. FATF Mutual Evaluation undertaken in February 2008. What are the high level requirements for verification of customer identification information (individuals and legal entities)? A9. Q10. This publication has been prepared for general guidance on matters of interest for the personal use of the reader. natural persons appointed to act on a customer’s behalf and beneficial owners. Q13. Where copies of identification documentation are provided. its members. and enquire if any beneficial owner exists in relation to a customer. and/or b) where the financial institution suspects that money laundering or terrorist financing is involved. Q16. In what circumstances is enhanced customer due diligence measures required? A13. a bank shall satisfy itself of the money laundering risks and perform the following: a) assessing the suitability of the respondent bank. This includes a) verification using reliable. All rights reserved. if it is satisfied that the risks of money laundering and terrorist financing are low. http://www. if it is satisfied that the risks of money laundering and terrorist financing are low (certain conditions apply). What enhanced due diligence must be performed for correspondent banking relationships (cross-border banking and similar relationships)? A15. Your Customer’ quick reference guide Yes. Generally. However the extent of due diligence performed may vary based on the risk. The application and impact of laws can vary widely based on the specific facts involved. Q12.fatf-gafi. You should not act upon the information contained in this publication without obtaining specific professional advice. 2 nd follow-up report was performed in February 2011. Enhanced customer due diligence measures are required to be taken in situations such as: a) when dealing with Politically Exposed Persons ('PEPs'). financial institutions may consider accepting documents that are certified to be true copies by qualified persons. employees and . to the extent permitted by law. No representation or warranty (express or implied) is given as to the accuracy or completeness of the information contained in this publication.pdf Country by country comparison of high level Know Your Customer and Anti-Money Laundering information Questions and Answers: ‘Know Your Customer’ quick reference guide Customer due diligence Q8. and b) retaining copies of all reference documents used to verify the identity of these persons. such as: a) where the customer originates from or is based in a country/jurisdiction known to have inadequate AML/CFT measures. In what circumstances is additional due diligence required for Politically Exposed Persons (‘PEPs’)? A14. each of which is a separate and independent legal entity. Q11. please find a link to a relevant report (if publicly available). independent sources.  Q9. in respect of simplified customer due diligence. © 2009 PricewaterhouseCoopers. Customer due diligence is required. Where the customer provides copies and not original identification documents. Requirement to identify and verify customers. However simplified customer due diligence arrangements are not allowed in certain circumstances. Are relationships with shell banks specifically prohibited? . Financial institutions may perform simplified customer due diligence measures it considers adequate to effectively identify and verify the identity of the customer. and c) obtaining approval from the bank's senior management to provide new correspondent banking services. 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. Q14. For example. b) when dealing with types of customers. PricewaterhouseCoopers LLP. Q15.org/media/fatf/documents/reports/mer/FoR%20Singapore. a natural person appointed to act on the customer’s behalf and any beneficial owner. and. Where there is one or more beneficial owner (s) in relation to a customer. “PricewaterhouseCoopers” refers to the network of member firms of PricewaterhouseCoopers International Limited. a natural person appointed to act on the customer’s behalf and any beneficial owner. There are requirements to take reasonable measures to understand the ownership and control structure of the customer.

http://www. Yes. You No representation should not or warranty act upon (express the information or implied) is given as contained in this publication without obtaining specific professional to the accuracy advice. No representation or warranty (express Q17. Tell us what matters to you and find out more by visiting us at www. and does not constitute professional advice. relationships? LLP.? A20. in reliance members. tipping off? A22. other transactions etc. to the extenttransactions and/or permitted by law. Does the local legislation allow transactions to be monitored outside the jurisdiction? A25. responsibility or duty of care for any consequences of you or anyone else acting. There is no de-minimis threshold. This publication has been prepared for general guidance on matters of interest only. Yes but subject to compliance with conditions and restrictions. . be required contact. We’re a network of firms in 158 countries with more than 180. PwC helps organisations and individuals create the value they’re looking for. each of which is a separate and independent legal entity.cad. b) documenting the respective AML/CFT responsibilities of each bank. Suspicious Activity Reports (SARs) are reported to Commercial Affairs Department of Singapore . unusual transactions. employees and PricewaterhouseCoopers agents do not accept or assume any liability. To whom are Suspicious Activity Reports (SARs) made? Please include a link to their website. Is there a requirement to obtain authority to proceed with a current/ongoing transaction that is identified as suspicious? A24.  . What was the volume of SARs made to the authorities in the most recent year? Please state the GDP for the equivalent year. or refraining to act. A17. This publication has been prepared for general guidance on matters of interest for the personal use of the reader.g. Are there any de-minimis thresholds below which transactions do not need to be reported? A21. Q24. Where there is All © 2009 PricewaterhouseCoopers. . norights as those International PricewaterhouseCoopers face-to-face that wouldLimited. Prohibited to enter into or continue correspondent banking relations with a shell bank. responsibility or duty of care for any consequences in this publication or for any decision based on it. carry of out contact. Laundering information Country by country comparison of high level Know Your Customer and Anti-Money Laundering information Q16.sg/amlcft/stro/ Q19. All rights reserved. What enhanced due diligence must be performed for correspondent banking relationships (cross-border banking and similar relationships)? Questions and Answers: ‘Know A15. in reliance on the information contained in this publication or for any decision based on it. 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. “PricewaterhouseCoopers” refers to the network of member firms of PricewaterhouseCoopers International Limited. Information on the volume of SARs is not publicly available. in reliance on the information contained in this publication or for any decision based on it. a bank shall satisfy itself of the money laundering risks and perform the following: Answers: a) assessing the suitability of the respondent bank. customer due diligence measures that are as stringent  Reporting Q18. international wire transfers. and does not constitute professional advice. The emphasis is on the suspicious nature of the transaction rather than the quantum. Q15. Are there any obligations to report anything more than suspicious transactions e. and does specific not constitute professional advice. and. The application and impact of laws can vary widely based on the specific facts involved. You should not act upon This publication has been prepared for general guidance on matters the information of interest contained in thisforpublication the personal use ofobtaining without the reader. its on or refraining to act. professional advice. its members. “PricewaterhouseCoopers” to be each of which is aperformed institution refers is required to the network separate andifindependent there were of membertofirms face-to-face legal entity. In all circumstances.000 people who are committed to delivering quality in assurance. Are there any penalties for non compliance with reporting requirements e. Are there any requirements (legal or regulatory) to use automated Suspicious Transaction monitoring technology? A23. Yes. Q22. and. Q23. Are relationships with shell banks specifically prohibited? A16. 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.pwc. Under the Monetary Authority of Singapore (Anti-Terrorism Measures) Regulations 2002.ontothe thespecific facts involved. © 2009 PricewaterhouseCoopers. You should not act upon the information contained in this publication without obtaining specific professional advice. cash transactions above a certain threshold. PricewaterhouseCoopers acting. to the any consequences of extent you orpermitted anyone elseby law. Q25. of you or anyone else acting. or refraining to act. the financial reserved. A14. information or responsibility contained in thisforpublication. extent permitted NoPwC by law.g. The application or completeness and impact of the information of laws can contained vary in this widely based publication. LLP. Questions Your and Customer’ quick reference guide Generally.com. No. duty of care and.gov. representation does do notor accept warrantyor(express assume or implied) is given as to the accuracy or completeness of the any liability. Q21. Q20. and ‘Know Your Customer’ quick reference guide c) obtaining Country by country approval from comparison of highthe bank's level senior Knowmanagement Your Customerto provide andnew correspondent Anti-Money banking services. Reporting to Commercial Affairs Department of Singapore is made based on unusual transactions and transactions beyond certain threshold. employees the information and contained agents do not accept or assume any liability. A18. tax and advisory services. A19.

casinos.prior to the 2007 amendments of the AML regulations.). where available. individual member firms of the PwC network.go. PwCIL does not provide any services to clients. Customer due diligence has been self-controlled by each financial institution and is now compulsory in the 2007 regulations. what are the various thresholds in place? A8. Korea General Q1.USD 5. Who is the regulator for AML controls for: (a) Banking. Transactions less than KRW 10.jung@kr. In what year did the relevant AML laws and regulations become effective? A1. 2001 (amended 2005. 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. Q6. Not for further distribution without the permission of PwC. each of which is a separate and independent legal entity. A7. (b) Other financial Services. (c) Non financial sector (e. Tel: + 82 2 3781 9381 Yongsanku. as the context requires. Under the 2007 amendments. Q5. customer due diligence should be conducted. No member firm is responsible or liable for the acts or omissions © 2009 PricewaterhouseCoopers. Is there any practical guidance provided to firms by public authorities regarding AML requirements. under which customer due diligence is not required? If Yes. If the aggregated amount exceeds this threshold. Relevant report is available at the FATF Website (Link). © 2013 PwC. Is a risk based approach approved by the local regulator(s)? A6. http://www. 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. Yes. responsibility for customer due diligence and filing of Cash Transaction Reports (CTRs) was imposed.com/ LS Yongsan Tower. A4. member firm nor can it control “PricewaterhouseCoopers” refers the exercise to the of another network PricewaterhouseCoopers International Limited. or. If the AML laws and/or regulations became effective in the last 2 years. The Design Group 21383 (01/13) member of member  firm’s professional judgment or bind another member firm or PwCIL in any way. Yes .KRW 10. Q3. what were the requirements of the previous AML regime? A2. firms of .000. 140-702. Under the 2005 amendment. Q2. Is there a requirement to retrospectively verify the identity of customers before the date the new AML regime was introduced? A5.kr/) is the regulator for AML for financial institutions.pwc.g. of any other All rights reserved.com 191 Hangangro 2ga. Are there minimum transaction thresholds. a risk based approach is compulsory and guidelines have been prepared. high value goods etc. KoFIU has been provided guidelines for regional AML Requirements (Link).the amendments made in 2007 require entities to retrospectively verify the identity of high risk customers only. Seoul. Customer due diligence Q8. a risk based approach to customer due diligence was optional.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 Customer and andAnti-Money Anti-Money Laundering Laundering information information South Korea Key contact: Hee-Chul Jung Postal address: Last updated: Email: hee-chul. Please include link to the regulator(s) website A3. Korea Financial Intelligence Unit (KoFIU. All rights reserved. Korea has been the subject of a FATF Mutual Evaluation. Yes . Each member firm is a separate legal entity and does not act as agent of PwCIL or any other member firm. Q4. with stricter customer due diligence and money laundering regulations implemented in 2007). The minimum thresholds for occasional transactions under which customer due diligence is not required are as follows: . and .000 or equivalent in the case of a transaction in a foreign currency. beyond the FATF recommendations and local legislation? Please include link to website. January 2013 hcjung@samil.000. “PwC” refers to the network of member firms of PricewaterhouseCoopers International Limited (PwCIL). Q7.000 should be aggregated over a certain period.kofiu. Yes – in 2009.000.

A6. b) cash payments and receipts with the central and provincial governments and public institutions. and ‘Know Your Customer’ quick reference guide . registration number. private banking. address. Country by country comparison of high level Know Your Customer and Anti-Money Laundering information Customer due diligence Q8. None stated in local regulations or guidance. ‘Know A7. The andthresholds minimum Answers: for occasional transactions under which customer due diligence is not required are as follows: . category of business.KRW 10. Where copies of identification documentation are provided.000. address of headquarters and branches. Identification and verification processes of customers have been strengthened in the updated regulations and guidance. In what circumstances is enhanced customer due diligence measures required? A13. Country customer due diligence should be conducted. Yes . Questions Q7. 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. What are the high © 2009 PricewaterhouseCoopers. please find a link to a relevant report (if publicly available). Are relationships with shell banks specifically prohibited? A16. Individual (including agent): Name. Non-profit organisation or others: Organisation name. contact and name of owner. although there is no detailed guidance on this. 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. each of which is a separate and independent legal entity.000. identification number. Yes. such as Automated Teller Machine (ATM) transactions. If the aggregated amount exceeds this threshold. Q16. by country comparison of high level Know Your Customer and Anti-Money Laundering information Q9. In what circumstances is additional due diligence required for Politically Exposed Persons (‘PEPs’)? A14. Has and Answers: the country been the subject of a FATF (or FATF-style) Mutual Evaluation or IMF assessment exercise in the last three years? If yes. Q10. date of birth. Q15. nationality. category of business. address and contact (phone number. and c) cash payments and receipts that are prescribed in the presidential decree because the transactions have no risk of money laundering. a risk based approach is compulsory and guidelines have been prepared. Under the 2007 amendments.prior to the 2007 amendments of the AML regulations. of  (individuals and legal entities)? A9. .000 should be aggregated over a certain period. Simplified due diligence has been included in the updated regulations and guidance. Korea has been the subject of a FATF Mutual Evaluation. under which customer due diligence is not required? If Yes. All rights requirements for verification “PricewaterhouseCoopers” of customer refers identification to the network of member firmsinformation PricewaterhouseCoopers International Limited. Profit organisation: Corporate name. including verification of beneficial ownership. contacts and name of owner. such as Politically Exposed Persons (‘PEPs’). what are the requirements around independent verification or authentication? A10. Q12. In what circumstances are reduced/simplified due diligence arrangements available? A12. registration number. Q17. The revision to regulations in 2005 allows for some exceptions as follows: a) cash payments and receipts between financial institutions. What enhanced due diligence must be performed for correspondent banking relationships (cross-border banking and similar relationships)? A15.000 or equivalent in the case of a transaction in a foreign currency. correspondent banking and terrorist facilitators/financiers. Q13. email address).000.USD 5. In what circumstances is additional due diligence required for non face-to-face transactions and/or relationships? Financial institutions must ensure that all electronic financial services and products. Relevant report is available at the FATF Website (Link). What are the high level requirements around beneficial ownership (identification and verification)? A11. Your Customer’ quick reference guide Yes – in 2009. what are the various thresholds in place? Questions A8. Q11. Are there minimum transaction thresholds. Q14. Transactions less than KRW 10. a risk based approach to customer due diligence was optional. The updated regulations recommend that enhanced due diligence is performed for correspondent banking relationships. levelreserved. The updated regulations recommend that enhanced customer due diligence is applied to overseas PEPs.

No representation or warranty (express or implied) is given as to the accuracy or completeness of the information contained in this publication. responsibility or duty of care for any consequences of you or anyone else acting. Q16. Are there any penalties for non compliance with reporting requirements e. Korea Financial Intelligence Unit (KoFIU) required Suspicious Activity Report (http://www. A13. and must implement them when establishing new business relationships and conducting ongoing customer due diligence. Volume of SARs 2011 – 329. Q25.247 million (Source: data. Q17. such as Automated Teller Machine (ATM) transactions. employees and agents do not accept or assume any liability. tipping off? A22. Q22. Activity All rights reserved. You should not act upon the information Reporting contained in this publication without obtaining specific professional advice. a link of member firms to of their website. by country comparison of high level Know Your Customer and Anti-Money Laundering information Country The updated regulations recommend that enhanced customer due diligence is applied to overseas PEPs. international wire transfers.000. to the extent permitted by law. Q21.000 to KoFIU. and does not constitute professional advice.463 SARs (KoFIU) GDP (in current prices): 2011 – USD1. cash transactions above a certain threshold. What was the volume of SARs made to the authorities in the most recent year? Please state the GDP for the equivalent year. No.kr).go.Financial institutions must ensure that all electronic financial services and products. Q19. A19. are based on accounts established through face-to-face identification. its members. What enhanced due diligence must be performed for correspondent banking relationships (cross-border banking and similar relationships)? A15. Are there any requirements (legal or regulatory) to use automated Suspicious Transaction monitoring technology? A23.  A18. Are relationships with shell banks specifically prohibited? A16.worldbank.g. other transactions etc. and. Questions and Answers: ‘Know Q14. To whom are Suspicious © 2009 PricewaterhouseCoopers. linked or individual transactions identified as suspicious should be reported to KoFIU. such as Politically Exposed Persons (‘PEPs’). Yes – imprisonment for a period not exceeding 1 year or a fine not exceeding KRW5 million per individual responsible for SAR reporting. 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. Financial institutions must also have policies and procedures in place to address any specific risks associated with non face-to-face transactions. unusual transactions.? A20. Q15. The application and impact of laws can vary widely based on the specific facts involved.8 million of GDP.116. in reliance on the information contained in this publication or for any decision based on it.000.org* ) This results in a ratio of 1 SAR for every USD2. Are there any obligations to report anything more than suspicious transactions e. Are there any de-minimis thresholds below which transactions do not need to be reported? A21.g.kofiu. or refraining to act. Is there a requirement to obtain authority to proceed with a current/ongoing transaction that is identified as suspicious? A24. Q20. This publication has been prepared for general guidance on matters of interest for the personal use of the reader. Yes – below KRW1. Reports (SARs) made? “PricewaterhouseCoopers” Please refers to the networkinclude PricewaterhouseCoopers International Limited. Yes. Q18. each of which is a separate and independent legal entity. private banking. ‘Know Your Customer’ quick reference guide internet banking and telephone banking. PricewaterhouseCoopers LLP. Yes – financial institutions in Korea have obligations for Currency Transaction Reports (CTR). which is the requirement for reporting transaction above KRW20. but transferring information of individual and financial transaction is prohibited by . Does the local legislation allow transactions to be monitored outside the jurisdiction? No – local AML regulations do not mention this issue. Country by country comparison of high level Know Your Customer and Anti-Money Laundering information . Q24. Q23.000 occasional transactions. In what circumstances is additional due diligence required for non face-to-face transactions and/or relationships? Questions and Answers: A17. correspondent banking and terrorist facilitators/financiers. The updated regulations recommend that enhanced due diligence is performed for correspondent banking relationships. Your Customer’ quick reference guide In what circumstances is additional due diligence required for Politically Exposed Persons (‘PEPs’)? A14. Yes – on transaction monitoring progress.

responsibility or duty of care for any consequences of you or anyone else acting. No. Yes – below KRW1. and. 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. It is agents do not accept or assume any liability.  This publication has been prepared for general guidance on matters of interest for the personal use of the reader. or refraining to act. You should not act upon the information contained in this publication without obtaining specific professional advice. Q25. PricewaterhouseCoopers All rights reserved. tipping off? A21. to the extent permitted by law. All rights reserved. We’re a network of firms in 158 countries with more than 180. Your Customer’ quick reference guide Are there any de-minimis thresholds below which transactions do not need to be reported? Are there any penalties for non compliance with reporting requirements e. tipping off? Are there any requirements (legal or regulatory) to use automated Suspicious Transaction monitoring technology? A22. You should not act upon the information contained in this publication without obtaining specific professional advice.S. an ©alternative . For a few countries where the official exchange rate does not reflect the rate effectively applied to actual foreign exchange transactions. Dollar figures for GDP are converted from publication or for any decision based on it. Q24.000. A23. tax and advisory services. in reliance on the information contained in this calculated without making deductions for depreciation of fabricated assets or for depletion and degradation of natural resources. and does not constitute professional advice. conversion factor is used. responsibility or duty of care for any consequences of you or anyone else acting. other transactions etc. * 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.pwc. Yes – on transaction monitoring progress.com. No. This publication has been prepared for general guidance on matters of interest only. each of which is a separate and independent legal entity. The application and impact of laws can vary widely based on the specific facts involved. employees and agents do not accept or assume any liability. Yes – imprisonment for a period not exceeding 1 year or a fine not exceeding KRW5 million per individual responsible for SAR reporting. in reliance on the information contained in this publication or for any decision based on it. No representation or warranty (express or implied) is given as to the accuracy or completeness of the information contained in this publication. 2009 PricewaterhouseCoopers. Data are in current U. .000 people who are committed to delivering quality in assurance. Dollar figures for GDP are converted from domestic currencies using single year official exchange rates. .000 occasional transactions. The application and impact of laws can vary widely based on the specific facts involved. and. Yes – on transaction monitoring progress. Questions and Answers: ‘Know Q21. You should not act upon the information contained in this publication without obtaining specific professional advice. its members. to the extent permitted by law. Q22. but transferring information of individual and financial transaction is prohibited by Korean privacy regulations. It is calculated without making deductions for depreciation of fabricated assets or for depletion and degradation of natural resources.000 occasional KRW20. Is there a requirement to obtain authority to proceed with a current/ongoing transaction that is identified as suspicious? Does the local legislation allow transactions to be monitored outside the jurisdiction? A24. to the extent permitted by law. “PricewaterhouseCoopers” refers to the network of member firms of International Limited. Tell us what matters to you and find out more by visiting us at www. No – local AML regulations do not mention this issue. This publication has been prepared for general guidance on matters of interest for the personal use of the reader.g. each of which is a separate and independent legal entity.000. employees and * 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. PricewaterhouseCoopers LLP.g. A24. 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. PwC does do not accept or assume any liability. “PricewaterhouseCoopers” refers to the network of member firms of PricewaterhouseCoopers International Limited. No representation or warranty (express or implied) is given as to the accuracy or completeness of the information contained in this publication. international wire transfers. or refraining to act. PricewaterhouseCoopers LLP. an alternative conversion factor is used. Yes – financial institutions in Korea have obligations for Currency Transaction Reports (CTR). Q25. Does the local legislation allow transactions to be monitored outside the jurisdiction? A25.000 transactions.000. and does not constitute professional advice. Q23. which is the requirement for reporting A21. Q23. responsibility or duty of care for any consequences of you or anyone else acting. or refraining to act. Yes – belowabove transaction KRW1. but transferring information of individual and financial transaction is prohibited by Korean privacy regulations. dollars. by Country A22. No – local AML regulations do not mention this issue. to KoFIU. linked or individual transactions identified as suspicious should be reported to KoFIU. © 2009 PricewaterhouseCoopers. Are there any penalties for non compliance with reporting requirements e. For a few countries where the official exchange rate does not reflect the rate effectively applied to actual foreign exchange transactions. threshold. Data are in current U. and. domestic currencies using single year official exchange rates. Are there any de-minimis thresholds below which transactions do not need to be reported? A20. Q22. No representation or warranty (express or implied) is given as to the accuracy or completeness of the information contained in this publication. in reliance on the information contained in this publication or for any decision based on it.  PwC helps organisations and individuals create the value they’re looking for. dollars.? Q21.S. A25. Q24. linked or individual transactions identified as suspicious should be reported to KoFIU. its members. and does not constitute professional advice.

as well as the authority and identification of all persons purporting to act on their behalf. local central bank) issues “Key Prudential Regulations” on Money Laundering for bank and non-bank financial institutions regulated by the BSP: http://www.pwc / 8767 Paseo de Roxas. including their subsidiaries and affiliates. only Covered Institutions are mandated by the AMLA to submit covered and suspicious transaction reports to the AMLC. Philippine Republic Act (R. each of which is a separate and independent legal entity.).gov. Q4. On 7 March 2003.arciga@ph. The Design Group 21383 (01/13) of member of another firms of member  firm’s professional judgment or bind another member firm or PwCIL in any way. where available. supervised and regulated by the BSP (or Philippine Central Bank). None stated in local regulations or guidance. (b) Other financial Services. The Anti Money Laundering Council (AMLC) of the Philippines . casinos. January 2013 Email: jenny. as the context requires. comma.http://www. “pre-need” companies. A4. Philamlife Tower. “PwC” refers to the network of member firms of PricewaterhouseCoopers International Limited (PwCIL). Who is the regulator for AML controls for: (a) Banking. Is a risk based approach approved by the local regulator(s)? A6. In what year did the relevant AML laws and regulations become effective? A1. 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. please find a link to a relevant report (if publicly available). “Anti Money Laundering Act (AMLA) at a Glance” summary: http://www.gov. No. These are: a) banks and all other entities. The Implementing Rules and Regulations took effect on 2 April 2002. responsible All rights reserved.amlc. A7.A.A.amlc. Corazon Postal address: Last updated: Echavez 29th Floor. Not for further distribution without the permission of PwC. (c) Non financial sector (e.ph/ . Q3.asp Q5.ph/amla. Is there a requirement to retrospectively verify the identity of customers before the date the new AML regime was introduced? A5.g. None.bsp. They shall maintain a system of verifying their legal existence and organisational structure. No member firm is © 2012 PricewaterhouseCoopers. high value goods etc. 9160) was signed into law and took effect on 23 March 2003. 9194 (An Act Amending R. Each member firm is a separate legal entity and does not act as agent of PwCIL or any other member firm. 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. All rights reserved. beyond the FATF recommendations and local legislation? Please include link to website.pwc. Q6. Q2.gov. No.A. If the AML laws and/or regulations became effective in the last 2 years. b) insurance companies and all other institutions supervised or regulated by the Insurance Commission. .ph/regulations/key_aml. No. Makati City 1226. It should be noted that under R.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 Customer and andAnti-Money Anti-Money Laundering Laundering information information Philippines Key contact: Jenny Arciga / Ma. Only Covered Institutions are required to establish and record the true identity of their clients based on official documents. The revised Implementing Rules and Regulations took effect on 7 September 2003. individual member firms of the PwC network. 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. © 2013 PwC. Is there any practical guidance provided to firms by public authorities regarding AML requirements. R. 9160. 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.corazon.echavez@ph.A. Please include link to the regulator(s) website A3. PwCIL does not provide any services to clients.html The Bangko Sentral ng Pilipinas (BSP. N/A.) No. or. what were the requirements of the previous AML regime? A2. foreign exchange corporations and other entities supervised or regulated by the Philippine Securities and Exchange Commission. Q7. and c) securities dealers. or liable for the acts or omissions “PricewaterhouseCoopers” of any other refers the member firm nor can it control to the network exercise PricewaterhouseCoopers International Limited.com Philippines Tel: +63 (2) 845 2728 3012 3171 General Q1.

employees and agents do not accept or assume any liability. or that its business or operations have not been or are not in the process of being closed. Though it is not defined in the local regulations or guidance. each of which is a separate and independent legal entity. Are there minimum transaction thresholds. bearing a photograph of the customer. or by an independent lawyer or public notary (in the case of certifications and affidavits issued by an individual). what are the various thresholds in place? A8. None stated in local regulations or guidance. All rights reserved. copies of Articles of Incorporation / Partnership should be certified by the Securities and Exchange Commission). as a common business practice. “PricewaterhouseCoopers” refers to the network of member firms of PricewaterhouseCoopers International Limited. nominee. c) Permanent address. Covered Institutions shall retain accounts only in the true and full name of the account owner or holder. In what circumstances are reduced/simplified due diligence arrangements available? A12. j) Source of funds. shut down. Q12. But regardless of whether these are covered transactions. What are the high level requirements around beneficial ownership (identification and verification)? A11. The provisions of existing Philippine laws regarding anonymous accounts. d) Date and place of birth.Questions andAnswers: Questions and Answers: ‘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 Anti-Money Laundering Launderinginformation information Customer due diligence Q8. f) Nature of work and name of employer or nature of self- employment/business.g. You should not act upon the information contained in this publication without obtaining specific professional advice. e) List of principal stockholders owning at least 2% of the capital stock.600). PricewaterhouseCoopers LLP. GBP7. what are the requirements around independent verification or authentication? A10. The application and impact of laws can vary widely based on the specific facts involved. What are the high level requirements for verification of customer identification information (individuals and legal entities)? A9. responsibility or duty of care for any consequences of you or anyone else acting. and does not constitute professional advice. and. i) Specimen signature. Where copies of identification documentation are provided. Individuals: The following minimum information/documentation shall be obtained from individual customers: a) Name. d) List of directors / partners. None stated in local regulations or guidance. or refraining to act. No representation or warranty (express or implied) is given as to the accuracy or completeness of the information contained in this publication.000 within one banking day (equates to approx. in reliance on the information contained in this publication or for any decision based on it. In what circumstances is enhanced customer due diligence measures required? A13. This publication has been prepared for general guidance on matters of interest for the personal use of the reader. Q10. Examples of such documents are identity cards and passports. b) By-laws. including shell companies and corporations: a) Articles of Incorporation / Partnership. the establishment and recording of the true identity of clients of Covered Institutions would cover all their clients. Q13. and all other similar accounts shall be prohibited. and h) Verification of the authority and identification of the person purporting to act on behalf of the client. g) Beneficial owners. In what circumstances is additional due diligence required for Politically Exposed Persons (‘PEPs’)? A14. f) Contact numbers. banks and other institutions require copies of original documents to be certified as true copies by the issuing agency (e. 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. Social Security System number or Government Services and Insurance System number. agent or in any capacity for and on behalf of another. The AMLA defines ‘covered transactions’ as single transactions in cash or other equivalent monetary instruments involving a total amount in excess of PHP500. g) Contact numbers. accounts under fictitious names. Q14. None. Q9.  . . When dealing with customers who are acting as trustee. Covered Institutions shall verify and record the true and full identity of the person(s) on whose behalf a transaction is being conducted. Corporate/Judicial Entities: Before establishing business relationships. Q11. None stated in local regulations or guidance. Corporate and Judicial Entities: The following minimum information/documentation shall be obtained from customers that are corporate or judicial entities. c) Official address or principal business address. its members. if any. 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. h) Tax identification number. b) Present address. to the extent permitted by law. © 2009 PricewaterhouseCoopers. and k) Names of beneficiaries in cases of insurance contracts. Individuals: Covered Institutions shall require customers to produce original documents of identity issued by an official authority. phased out. under which customer due diligence is not required? If Yes. e) Nationality.

Questions and Answers:
Questions and Answers:
‘Know Your
‘Know Your Customer’
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Country by country comparison of high level Know Your Customer and Anti-Money Laundering information
Country by country comparison of high level Know Your Customer and Anti-Money Laundering information

Q15. What enhanced due diligence must be performed for correspondent banking relationships (cross-border banking and similar relationships)?

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.

Q16. Are relationships with shell banks specifically prohibited?

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.

Q17. In what circumstances is additional due diligence required for non face-to-face transactions and/or relationships?

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

Q18. To whom are Suspicious Activity Reports (SARs) made? Please include a link to their website.

A18. AMLC: http://www.amlc.gov.ph/assistance.html

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. 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 client’s 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.

Q21. Are there any de-minimis thresholds below which transactions do not need to be reported?

A21. Refer to Q20 above.

Q22. Are there any penalties for non compliance with reporting requirements e.g. tipping off?

.
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
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 for any decision based on it.
© 2009 PricewaterhouseCoopers. All rights reserved. “PricewaterhouseCoopers” refers to the network of member firms of
PricewaterhouseCoopers International Limited, each of which is a separate and independent legal entity. 

c) the transaction is structured to avoid being the subject of reporting requirements under the AMLA;
d) there is a deviation from the client’s 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.

Questions and Answers:
‘Know
Q21.
Questions Your
and Customer’ quick reference guide
Are there any de-minimis thresholds below which transactions do not need to be reported?
Answers:
‘Know Your Customer’ quick reference guide
A21. by country comparison of high level Know Your Customer and Anti-Money Laundering information
Country
Refer to Q20 above.

Country by country comparison of high level Know Your Customer and Anti-Money Laundering information
Q22. Are there any penalties for non compliance with reporting requirements e.g. tipping off?

. 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
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 thisaccount.
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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
publication or for any decision based on it.
information relative to money laundering transaction against any person. Penalty is 6 months to 4 years imprisonment and a fine of not less
© 2009 PricewaterhouseCoopers. All rights reserved. “PricewaterhouseCoopers” refers to the network of member firms of
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
PricewaterhouseCoopers International Limited, each of which is a separate and independent legal entity.
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.

Q23. Are there any requirements (legal or regulatory) to use automated Suspicious Transaction monitoring technology?

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

Q24. Is there a requirement to obtain authority to proceed with a current/ongoing transaction that is identified as suspicious?

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.

Q25. Does the local legislation allow transactions to be monitored outside the jurisdiction?

A25. No.

PwC helps organisations and individuals create the value they’re looking for. We’re a network of firms in 158 countries with more than 180,000
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.
. This publication has been prepared for general guidance on matters of interest only, and does not constitute professional advice. You should not act upon
This publication has been prepared for general guidance on matters
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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
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
publication or for any decision based on it.
© 2009 PricewaterhouseCoopers. All rights reserved. “PricewaterhouseCoopers” refers to the network of member firms of
PricewaterhouseCoopers International Limited, each of which is a separate and independent legal entity. 

Questions and
Questions andAnswers:
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‘Know Your
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Country by
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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

Q1. In what year did the relevant AML laws and regulations become effective?

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

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. Before issuance of the AML Act in 2010, the AML Ordinance was issued in 2007 by the President of Pakistan.

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. 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/

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. 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

Q5. Is there a requirement to retrospectively verify the identity of customers before the date the new AML regime was introduced?

A5. Yes.

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

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.

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. 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

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. No threshold defined in the AML Act 2010. However, organisations have defined their own internal monetary thresholds.
© 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 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
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
© 2009 PricewaterhouseCoopers.
responsible All rights reserved.
or liable for the acts or omissions “PricewaterhouseCoopers”
of any other refers to
member firm nor can it control thethe network
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of of member
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scenarios/factors and general low risk scenarios/factors.

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,
Questions and Answers:
please find a link to a relevant report (if publicly available).

‘Know
A7. Your Customer’ quick reference guide
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
Country by country comparison of high level Know Your Customer and Anti-Money Laundering information

Customer due diligence
Questions and Answers:
Q8. Are there minimum transaction thresholds, under which customer due diligence is not required?
‘Know Your Customer’ quick reference guide
If Yes, what are the various thresholds in place?

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.
Laundering information

© 2009 PricewaterhouseCoopers. All rights reserved. “PricewaterhouseCoopers” refers to the network of member firms of

Q9.
PricewaterhouseCoopers
What areInternational
the high Limited, each of which is afor
level requirements separate and independent
verification legal entity.
of customer identification information

(individuals and legal entities)?

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 .

Q10. Where copies of identification documentation are provided, what are the requirements around independent verification or authentication?

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.

Q11. What are the high level requirements around beneficial ownership (identification and verification)?

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.

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

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.

Q13. In what circumstances is enhanced customer due diligence measures required?

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.

Questions and Answers:
Q12.In what circumstances are reduced/simplified due diligence arrangements available?

‘Know
A12.
Your Customer’ quick reference guide
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.
Country by country comparison of high level Know Your Customer and Anti-Money Laundering information

Q13. In what circumstances is enhanced customer due diligence measures required?

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,
Questions and Answers:
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.
‘Know Your Customer’ quick reference guide
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.
Country by country comparison of high level Know Your Customer and Anti-Money Laundering information
.
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
Q14. In what circumstances is additional due diligence required for Politically Exposed Persons (‘PEPs’)?
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
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 for any decision based on it.
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
PricewaterhouseCoopers International Limited, each of which is a separate and independent legal entity.
a) implement appropriate internal policies, procedures and controls to determine if a customer or beneficial owner is a PEP;

b) obtain approval from the bank’s 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.

Q15. What enhanced due diligence must be performed for correspondent banking relationships (cross-border banking and similar relationships)?

A15. Regulations 2 of SBP AML/CFT regulations cover this topic in detail.

Q16. Are relationships with shell banks specifically prohibited?

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.

Q17. In what circumstances is additional due diligence required for non face-to-face transactions and/or relationships?

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

Q18. To whom are Suspicious Activity Reports (SARs) made? Please include a link to their website.

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

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.

Q21. Are there any de-minimis thresholds below which transactions do not need to be reported?

A21. As per paragraph 7 of Regulation 4 of SBP AML/CFT regulations:

000 people who are committed to delivering quality in assurance. Are there any requirements (legal or regulatory) to use automated Suspicious Transaction monitoring technology? A23. should be reported regardless of the amount of the transactions.com. “PricewaterhouseCoopers” refers to the network of member firms of PricewaterhouseCoopers International Limited.g. The following are extracts from SBP AML/CFT Regulation No. other transactions etc. State Bank of Pakistan. Thereporting requirements application and impact of laws e. Yes by SBP.  Q23. for analysis and possible reporting of suspicious transactions. Country by country comparison of high level Know Your Customer and Anti-Money Laundering information Q20. © 2009 PricewaterhouseCoopers. Your Customer’ quick reference guide What was the volume of SARs made to the authorities in the most recent year? Please state the GDP for the equivalent year. You should not act upon the information contained in this publication without obtaining specific professional advice. in reliance on the information contained in this publication or for any decision based on it. Tell us what matters to you and find out more by visiting us at www. and. its members. publication or for any decision based on it. No. to the local regulator i. including attempted transactions. You should not act upon the information Q22. Are contained in this there any publication penalties without for nonprofessional obtaining specific compliance with advice. Is there a requirement to obtain authority to proceed with a current/ongoing transaction that is identified as suspicious? A24. No. or refraining to act. No. Country by the country comparison CTRs should be reported of high above thelevel Know threshold Your Customer of PKR2. and does not constitute professional advice.g. No representation or warranty (express or implied) is given as to the accuracy or completeness of the information contained in this publication. responsibility or duty of care for any consequences of you or anyone else acting. All rights reserved. Accordingly. http://www. No. Does the local legislation allow transactions to be monitored outside the jurisdiction? A25. tax and advisory services. Are there any de-minimis thresholds below which transactions do not need to be reported? Questions and Answers: ‘Know A21. PricewaterhouseCoopers LLP. This publication has been prepared for general guidance on matters of interest for the personal use of the reader. For banking organisations.org. This publication has been prepared for general guidance on matters of interest only. To whom are Suspicious Activity Reports (SARs) made? Please include a link to their website.pk/ Questions and Answers: ‘Know Q19. employees and agents do not accept or assume any liability. Q25.” . banks/DFIs shall establish criteria in their AML/CFT Policies for management of such alerts. PwC helps organisations and individuals create the value they’re looking for. cash transactions above a certain threshold. in reliance on the information contained in this A22. A19.? A20. We’re a network of firms in 158 countries with more than 180. Q21. Are there any obligations to report anything more than suspicious transactions e. responsibility or duty of care for any consequences of you or anyone else acting. . and. or refraining to act. PwC does do not accept or assume any liability. to the extent permitted by law. Further. Your Customer’ quick reference guide As per paragraph 7 of Regulation 4 of SBP AML/CFT regulations: “Banks/DFIs should note that STRs. international wire transfers. based on pre-defined parameters/thresholds and customer profile. and. and does not constitute professional advice. Information on the volume of SARs is not publicly available. No representation or warranty (express or implied) is given as to the accuracy or completeness of the information contained in this publication. to the extent permitted by law.5m and Anti-Money as per requirements Laundering information of AML Act. Q18.pwc. Q24. 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. unusual transactions. tipping can vary widelyoff? based on the specific facts involved.sbp.e. all banks/DFIs are advised to implement automated Transaction Monitoring Systems (TMS) capable of producing meaningful alerts in real time. A18. each of which is a separate and independent legal entity.

the Financial Markets Authority is the relevant AML/CFT supervisor: http://www. high value goods etc. non-deposit-taking lenders.govt. No member firm is © 2009 PricewaterhouseCoopers. and other reporting entities that are not covered by paragraph (a) or (b). Each member firm is a separate legal entity and does not act as agent of PwCIL or any other member firm.nz/ c) for casinos. please find a link to a relevant report (if publicly available).nz/aml/4512701.rbnz. 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.govt. trustee companies.nz/ Q4. futures dealers.). The Design Group 21383 (01/13) of member of another firms of member  firm’s professional judgment or bind another member firm or PwCIL in any way. and non-bank deposit takers. Is there any practical guidance provided to firms by public authorities regarding AML requirements.govt.pdf Q5. Reporting entities are required to be fully compliant within two years i. Q2. The current regime does not incorporate a risk based approach.pdf Auditing guideline: https://www.govt.fma. responsible All rights reserved.nz/aml/4616911. money changers.pdf Interpreting “Ordinary course of business”: http://www. PwCIL does not provide any services to clients.pdf Identity Verification Code of Practice: http://www. what were the requirements of the previous AML regime? A2. In what year did the relevant AML laws and regulations become effective? A1. (c) Non financial sector (e. N/A – previous regime still in force until 30 June 2013. Q7. there is no such requirement. However the new Act is risk based. the Department of Internal Affairs is the relevant AML/CFT supervisor: http://www. Is a risk based approach approved by the local regulator(s)? A6. For anonymous accounts.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 Anti-Money Laundering Laundering information information New Zealand Key contact: Stephen Drain Postal address: Last updated: Email: stephen.c.dia. A7. However. Auckland 1142. 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. Is there a requirement to retrospectively verify the identity of customers before the date the new AML regime was introduced? A5. in October 2009 the Anti-Money Laundering and Countering Financing of Terrorism Act 2009 was passed. . The current regime is captured under the Financial Transactions Reporting Act 1996. each of which is a separate and independent legal entity.html Customer due diligence © 2013 PwC. individual member firms of the PwC network. the Reserve Bank of New Zealand (Reserve Bank) is the relevant AML/CFT supervisor: http://www. and financial advisers. Not for further distribution without the permission of PwC. If the AML laws and/or regulations became effective in the last 2 years.govt. a) for banks.rbnz. Under the current regime. Yes – see following link: http://www. by 30 June 2013.drain@nz. collective investment schemes. Q6.govt. AML Programme guideline: http://www. Under the new Act.rbnz.org/documents/documents/mutualevaluationofnewzealand. Q3. Please include link to the regulator(s) website A3. A4. (b) Other financial Services.com Private Bag 92162.nz/media/1339626/guideline_for_audits_of_risk_assessments_and_aml_cft_programmes.e. life insurers. 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.nz/ b) for issuers of securities. “PwC” refers to the network of member firms of PricewaterhouseCoopers International Limited (PwCIL).g.fma. as the context requires.pwc. brokers.rbnz.fatf-gafi.govt. beyond the FATF recommendations and local legislation? Please include link to website. where available. or. Regulations to the Act were gazetted on 30 June 2011. or liable for the acts or omissions “PricewaterhouseCoopers” of any other refers the member firm nor can it control to the network exercise PricewaterhouseCoopers International Limited. Who is the regulator for AML controls for: (a) Banking. New January 2013 Tel: +64 9 355 8332 Zealand General Q1. 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.nz/aml/4533970. casinos. All rights reserved.

rbnz.html ‘Know Your Customer’ quick reference guide Country by country comparison of high level Know Your Customer and Anti-Money Laundering information Customer Country due comparison by country diligence of high level Know Your Customer and Anti-Money Laundering information © 2009 PricewaterhouseCoopers. Under the new Act. or c. a non-resident customer from a country that has insufficient anti-money laundering and countering financing of terrorism systems or measures in place. in reliance on the information contained in this Q14. a company with nominee shareholders or shares in bearer form.pdf Q10.govt. 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. The current regime does not incorporate a risk based approach. what are the requirements around independent verification or authentication? A10. c) travellers’ cheques NZD5. b) if a customer seeks to conduct an occasional transaction through the reporting entity and that customer is a. Simplified due diligence is essentially reduced measures for entities that are deemed to be lower risk i. 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. a complex. Where copies of identification documentation are provided. Q9. “PricewaterhouseCoopers” transaction thresholds. c) if a customer seeks to conduct. responsibility or duty of care for any consequences of you or anyone else acting. a non-resident customer from a country that has insufficient anti-money laundering and countering financing of terrorism systems or measures in place. The regulations also define the application of simplified due diligence in respect of section 18(1) of the Act. occasional (cash) transactions under NZD10.99. under which refers tocustomer the network due of member PricewaterhouseCoopers International Limited. This publication has been prepared for general guidance on matters of interest for the personal use of the reader. to the extent permitted by law. What are the high level requirements around beneficial ownership (identification and verification)? A11. The beneficial ownership threshold level is to be set at 25%. d) money & postal orders NZD1.000 will not require customer due diligence. However the new Act is risk based. You should not act upon the information contained in this publication without obtaining specific professional advice.000. or c. “Occasional Transactions” thresholds have been established. The only condition is that the first institution must satisfy itself that the other facility exists.999. what are the various thresholds in place? firms ofis diligence not required?  A8. In what circumstances is enhanced customer due diligence measures required? A13. Q8.000 or more. when there are three or more facility holder's signatories to an account. a trust or another vehicle for holding personal assets. Also. Requirements for verification of identity are explained in the following document : http://www. only the principal facility holder's identity has to be verified. Your and Customer’ quick reference guide Answers: Yes – see following link: http://www.000 . through the reporting entity. PricewaterhouseCoopers LLP.000. b. situation. This largely remains unchanged under the new regime. or d) when a reporting entity considers that the level of risk involved is such that enhanced due diligence should apply to a particular . Currently. © 2009 PricewaterhouseCoopers. and. 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. the Act is silent on the exact documentation considered reasonably capable of proving a person's identity. or refraining to act. employees and agents do not accept or assume any liability.nz/aml/4512701. b. A6. However. each of which is a separate and independent legal entity. In this case. The current Financial Transactions Reporting Act (1996) is relatively silent on enhanced customer due diligence. Under the new Act. Yes – under the current regime. and does not constitute professional advice. and e) foreign exchange transactions over NZD1.e. Q12.fatf-gafi. In what circumstances are reduced/simplified due diligence arrangements available? A12.org/documents/documents/mutualevaluationofnewzealand. If Yes. Questions and Answers: The new Act specifically deals with simplified CDD. 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. Country by country comparison of high level Know Your Customer and Anti-Money Laundering information Q13. No representation or warranty (express or implied) is given as to the accuracy or completeness of the information contained in this publication. 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. a company with nominee shareholders or shares in bearer form. All rights reserved. What are the high level requirements for verification of customer identification information (individuals and legal entities)? A9. Questions Q7. This means any individuals owning 25% (or more) of a customer would be subject to CDD requirements. 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. In what circumstances is additional due diligence required for Politically Exposed Persons (‘PEPs’)? publication or for any decision based on it. Are there minimum All rights reserved. Q11. The proposed legislation will likely prescribe what identity information is required. listed companies etc. b) cash transactions in a casino that are for NZD6. ‘Know Your Customer’ quick reference guide Government departments. “PricewaterhouseCoopers” refers to the network of member firms of . a trust or another vehicle for holding personal assets. its members. The application and impact of laws can vary widely based on the specific facts involved. Identification documents must be certified as a true copy by one of a number of categories of individuals. unusually large transaction or unusual pattern of transactions that have no apparent or visible economic or lawful purpose. ‘Know Questions A7. please find to a relevant report (if publicly available).

a trust or another vehicle for holding personal assets. b. What contained in this was without publication the volume ofspecific obtaining SARsprofessional made toadvice. or c. has verified the identity of. You should not act upon the information Q19. or d) relevant to the enforcement of the Proceeds of Crime Act 1991 or the Criminal Proceeds (Recovery) Act 2009. Not under the current regime but is prohibited under the new Act. including whether the respondent has been subject to a money laundering or financing of terrorism investigation or regulatory action.nz/service/financial . In what circumstances is additional due diligence required for non face-to-face transactions and/or relationships? A17. or c) relevant to the enforcement of the Terrorism Suppression Act 2002. and conducts ongoing monitoring in respect of. Volume publication or for of SARs: any decision 2010 – 4. This publication has been prepared for general guidance on matters of interest for the personal use of the reader. b) if a customer seeks to conduct an occasional transaction through the reporting entity and that customer is a. All rights reserved. Q20. Your Customer’ quick reference guide To whom are Suspicious Activity Reports (SARs) made? Please include a link to their website. facts the equivalent year.547 million (Source: data.357 SARs based on it. “PricewaterhouseCoopers” refers to the network of member firms of PricewaterhouseCoopers International Limited. the documents. in respect of those of the respondent’s customers who have direct access to accounts of the correspondent. the correspondent must: a) gather enough information about the respondent to understand fully the nature of the respondent’s business.  GDP (in current prices): 2010 – USD141. a company with nominee shareholders or shares in bearer form. ‘Know Your Customer’ quick reference guide c) if a customer seeks to conduct. Q17. systems or measures in place. Q21. Under the new regime. employees and agents do not accept or assume any liability. What enhanced due diligence must be performed for correspondent banking relationships (cross-border banking and similar relationships)? A15. 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. a non-resident customer from a country that has insufficient anti-money laundering and countering financing of terrorism Questions and Answers: systems or measures in place. and f) be satisfied that. and does not constitute professional advice. Under the new Act. to the extent permitted by law.govt. 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. Suspicious Country Transaction Reports (STRs) are made to the New Zealand Police’s Financial Intelligence Unit: by country comparison of high level Know Your Customer and Anti-Money Laundering information http://www.worldbank. or warranty (express No representation or implied) is given as to the accuracy or completeness of the information contained in this publication. in reliance on the information contained in this A19.police. and c) assess the respondent’s anti-money laundering and countering financing of terrorism controls to ascertain that those controls are adequate and effective. PricewaterhouseCoopers LLP. unusually large transaction or unusual pattern of transactions that have no apparent or visible economic or lawful purpose. The new Act requires foreign PEPs to undergo enhanced customer due diligence Q15. or information obtained when conducting the relevant customer due diligence and ongoing customer due diligence. or refraining to act. © 2009 PricewaterhouseCoopers. Under the current Financial Transactions Reporting Act (1996). The current Financial Transactions Reporting Act (1996) does not directly address PEPs. responsibility or duty of care for any consequences of you or anyone else acting. the respondent: a. a complex. and d) have approval from its senior management before establishing a new correspondent banking relationship. cash transactions above a certain threshold. In what circumstances is additional due diligence required for Politically Exposed Persons (‘PEPs’)? A14. Q16. data. a company with nominee shareholders or shares in bearer form.org*) This results in a ratio of 1 SAR for every USD32. A18.5 million of GDP. other transactions etc. its members. or b) relevant to the enforcement of the Misuse of Drugs Act 1975. Q14. lawyer etc) Reporting Questions and Answers: ‘Know Q18. the identity of those involved in non face-to-face transactions must be verified. and. the authorities in and The application theimpact mostofrecent laws canyear? Please vary widely basedstate on thethe GDP specific forinvolved. Are there any de-minimis thresholds below which transactions do not need to be reported? . Are relationships with shell banks specifically prohibited? A16. identity documents can be endorsed by one of a number of nominated persons (police officer. or c.? A20. international wire transfers. Are there any obligations to report anything more than suspicious transactions e. each of which is a separate and independent legal entity.g. those customers. or