Wotfsberg Group - Himalayan Bank...l"limalairan Bank Linltsd @ The Wolfsberg Group 2020 25 Has the...

wolfsberg Group correspondent Banking Due Diligence euestionnaire (cBDDe) v1.3

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Financial lnstitution Name:

Location (Country) :

ThequeStionnaireisrequiredtobeansweredonaLegalEn.ity(LE)Le,level including any branches for which the client base, products and control model are materially similar to the LE Head Office. This questionnaireshould not cover more than one LE. Each question in the CBDDQ will need to be addressed from the perspective of the LE and on behalf of all of itsbranches. lf a response for the LE differs for one of its branches, this needs to be highlighted and details regarding this difference captured at the endof each sub'section- lf a branch's business activity (products offered, client base etc.) is materially different than its Entity Head Office, a separatequestionnaire can be completed for that branch.

No# Question Answer1. EN: l Y &.OWN.ERS}||P,| ull Legal Name

Himalayan Bank Limited

2 \ppend a list of foreign branches which are:overed by this questionnaire All Branches, List of Branches in this Link: https://www.himalayanbank.com/branch

Full Legal (Registered) AddressKathmandu Metropolitan City, Ward No. 28, Kamaladi Kathmandu, Nepal

Full Primary Business Address (if different fromabove) Kathmandu Metropolitan City, Ward No. 28, Kamaladi Kathmandu, Nepal

Date of Entity incorporation/ establishment1992 Feburary 16

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6 Select type of ownership and append anownership chart if available

6a Publicly Traded (25o/o of shares publicly traded)Yes

6a1 lf Y, indicate the exchange traded on and tickersymbol Nepal Stock Exchange Limited (NEPSE)

6b Member Owned/ MutualNo

6c Government or State Owned by 25o/o or moreNo

5d Privately OwnedNo

5dl lf Y, provide details of shareholders or ultimatebeneficial owners with a holding of lOo/o or more

N/A

7 % of the Entity's total shares composed ofbearer shares N/A

Does the Entity, or any of its branches, operateunder an Offshore Banking License (OBL) ? No

3a lf Y, provide the name of the relevant branch/eswhich operate under an OBL

Name of primary financial regulator / supervisoryauthority Nepal Rastra Bank

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Wolfsberg Group Correspondent Banking Due Diligence Questionnaire (CBDDQ) V1.3

10 )rovide Legal Entity ldentifier (LEl) if available

11 Provide the full legal name of the ultimate parent(if different from the Entity completing the DDQ)

N/A

12 Jurisdiction of licensing authority and regulatorof ultimate parent

N/A

3 Select the business areas applicable to theEntity

13 a Retail BankingYes

13b )rivate Banking / Wealth ManagementNo

13 c lommercial BankingYes

13d fransactional BankingYes

'13 e lnvestment BankingNo

13 f Financial Markets TradingYes

139 Securities Services / CustodyNo

13 h 3roker / DealerNo

13 Vlultilateral Development BankNo

13 j f,ther

14 Does the Entity have a significant (10% or more)portfolio of non-resident customers or does itderive more than '10% of its revenue from non-resident customers? (Non-resident meanscustomers primarily resident in a differentjurisdiction to the location where bank servicesare provided.)

trr

No

14a lf Y, provide the top five countries where the non-resident customers are located.

15 Select the closest value:

15 a Number of employees501 -1 000

'15 b TotaI ASSetSGreater than $500 million

16 Confirm that all responses provided in the aboveSection ENTITY & OWNERSHIP arerepresentalive of all the LE's branches

Yes

16a lf N, clarify which questions the difference/srelate to and the branch/es that this applies to.

16b lf appropriate, provide any additional information/ context to the answers in this section.

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2. FRODUGfS $,$sRVl6[$17 foes the Entity offer the following products and

iervices:

't7 a Jorrespondent BankingNo

17 a1 fY

17 a2 )oes the Entity offer Correspondent Banking;ervices to domestic banks? No

17 a3 Does the Entity allow domestic bank clients toprov ide downstream relationships? No

17 a4 Does the Entity have processes and proceduresin place to identify downstream relationshipswith domestic banks?

No

'17 a5 foes the Entity offer correspondent banking;ervices to Foreign Banks? No

17 aG )oes the Entity allow downstream relationshipsrvith Foreign Banks? No

17 a7 Does the Entity have processes and proceduresin place to identify downstream relationshipswith Foreign Banks?

No

17 aB )oes the Entity offer correspondent banking;ervices to regulated MSBs/MVTS? No

17 a9 )oes the Entity allow downstream relationshipswith MSBs/MWS? No

17 a'10 )oes the Entity have processes and proceduresn place to identify downstream relationships,Vith MSB /MVTS?

No

17b )rivate Banking (domestic & international)No

17c Trade FinanceYes

17d rayable Through AccountsNo

17e Stored Value lnstrumentsNo

17t lross Border Bulk Cash DeliveryNo

17g )omestic Bulk Cash DeliveryNo

6

17h lnternational Cash LetterNo

17i Remote Deposit CaptureNo

't7 j /irtual /Digital CurrenciesNo

17k -ow Price SecuritiesNo

'17 I Hold MailNo

't7 m lross Border Rem ittancesYes

17n Service to walk-in customers (non-accountholders) Yes

17o Sponsoring Private ATMsNo

17p Other high risk products and services identifiedby the Entity

No

8 Confirm that all responses provided in the aboveSection PRODUCTS & SERVICES arerepresentative of all the LE's branches

Yes

8a lf N, clarify which questions the difference/srelate to and the branch/es that this applies to

,t8 b lf appropriate, provide any additional information/ context to the answers in this section.

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3. AML;,CfF & .S,ANGT|O NS,,pp96*AMME19 Does the Entity have a programme that sets

minimum AML, CTF and Sanctions standardsregarding the following components:

19 a Appointed Officer with sufficientexperience/expertise Yes

9b Cash ReportingYes

19 c CDDYes

19d EDDYes

19 e Beneficial OwnershipYes

't9 f lndependent TestingYes

199 Periodic ReviewYes

19h Policies and ProceduresYes

19 i Risk AssessmentYes

1sj SanctionsYes

19 k PEP ScreeningYes

19t Adverse lnformation ScreeningYes

9m Suspicious Activ ity ReportingYeS

19 n Training and EducationYes

19o Transaclion Mon itoringYes

20 How many full time employees are in the Entity'sAML, CTF & Sanctions ComplianceDepartment?'

Less than 10

21 ls the Entity's AML, CTF & Sanctions policyapproved at least annually by the Board orequivalent Senior Management Committee?

Yes f,}.

22 Does the Board or equivalent SeniorManagement Committee receive regularreporting on the status of the AMt-, CTF &Sanctions programme?

Quarterly/Every three months

23 Does the Entity use third parties to carry out anycomponents of its AML, CTF & Sanctionsprogramme?

No

23a lf Y, provide further details

24 Confirm that all responses provided in the aboveSection AML, CTF & SANCTIONS Programmeare representative of all the LE's branches

Yes


24b tf appropriate, provide any additional information/ context to the answers in this section.

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25 Has the Entity documented policies andprocedures consistent with applicable ABCregulations and requirements to [reasonably]prevent, detect and report bribery andcorruotion?

Yes

26 Does the Entity have an enterprise wideprogramme that sets minimum ABC standards?

No

27 Has the Entity appointed a designated officer orofficers with sufficient experience/expertiseresponsible for coordinating the ABCproqramme?

Yes

28 Does the Entity have adequate staff withappropriate levels of experience/expertise toimplement the ABC programme?

Yes

29 ls the Entity's ABC programme applicable to: Third parties acting on behalf of the Entity

30 Does the Entity have a global ABC policy that:

]0a Prohibits the giving and receiving of bribes?This includes promising, offering, giving,solicitation or receiving of anything of value,directly or indirectly, if improperly intended toinfluence action or obtain an advantage

Yes

30b ncludes enhanced requirements regardingnteraction with public officials?

Yes

a0c ncludes a prohibition against the falsification oflooks and records (this may be within the ABCrolicy or any other policy applicable to the Legalintitv)?

Yes

31 )oes the Entity have controls in place to monitor:he effectiveness of their ABC programme? Yes

32 Does the Entity's Board or Senior ManagementCommittee receive regular Managementlnformation on ABC matters?

Yes

!3 Does the Entity perform an Enterprise WideABC risk assessment?

No

13a lf Y select the frequency

,4 Does the Entity have an ABC residual risk ratingthat is the net result of the controls effectivenessand the inherent risk assessment?

No

]5 Does the Entity's ABC EWRA cover the inherentrisk components detailed below:

35a Potential liability created by intermediaries andother third-party providers as appropriate

Yes

35b Corruption risks associated with the countriesand industries in which the Entity does business,directly or through intermediaries

Yes

35c lransactions, products or services, including:hose that involve state-owned or state-:ontrolled entities or public officials

Yes

35d Sorruption risks associated with gifts androspitality, hiring/internships, charitablelonations and political contributions

Yes

35e Changes in business activities that maymaterially increase the Entity's corruption risk

Yes

36 Does the Entity's internal audit function or otherindependent third party cover ABC Policies andProcedures?

Yes

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37 Ooes tne Entity provide mandatory ABC training

to:

17a joard and senior Committee Management Yes

37b 1st Line of Defence Yes

37c

37d

2nd Line of Defence Yes

3rd Line of Defence Yes

37e 3rd parties to which specific complianceactivities subject to ABC risk have been

outsourced

Yes

t7t rlon-employed workers as appropriatelcontractors/consu ltants)

Yes

38 Ooes tfie entity provide ABC training that is

targeted to specific roles, responsibilities and

activities?

Yes

39 Confirm that all responses provided in the above

Section Anti Bribery & Corruption are

representative of all the LE's branchesYes

39a tt t t, ctarfy wnich questions the difference/srelate to and the branch/es that this applies to.

39b f appropriate, provide any additional information

'context to the answers in this section'

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wolfsberg Group correspondent Banking Due Diligence euestionnaire (cBoDo) v1.3

5. AML,40

CTF & SANCTIONS POLICIES_& PROCEHas the Entity documented policies andprocedures consistent with applicable AMI_, CTF& Sanctions regulations and requirements toreasonably prevent, detect and report:

)URES

40a Money launderingYes

40b ferrorist financingYes

40c Sanctions violationsYes

1 Are the Entity's policies and procedures updatedat least annually? Yes

t2 Are the Entity's policies and procedures gappedagainsl/compared to:

12a US StandardsNo

2a1 lf Y, does the Entity retain a record of theresults?

t2b EU StandardsNo

12 b1 lf Y, does the Entity retain a record of theresults?

t3 Does the Entity have policies and proceduresthat:

t3a Prohibit the opening and keeping of anonymousand fictitious named accounts Yes

13b Prohibit the opening and keeping of accounts forunlicensed banks and/or NBFIs Yes

43c Prohibit dealing with other entities that providebanking services to unlicensed banks Yes

3d )rohibit accounts/relationships with shell banksYes

43e )rohibit dealing with another entity that provides;ervices to shell banks Yes

43f Prohibit opening and keeping of accounts forSection 31'l designated entities

sYes439 Prohibit opening and keeping of accounts for

any of unlicensed/unregulated remittanceagents, exchanges houses, casa de cambio,bureaux de change or money transfer agents

Yes

3h Assess the risks of relationships with domesticand foreign PEPs, including their family andclose associates

Yes

3i Define escalation processes for financial crimerisk issues Yes

f3j Define the process, where appropriate, forterminating existing customer relationships dueto financial crime risk

Yes

{3k Specify how potentially suspicious activityidentified by employees is to be escalaled andinvestigated

Yes

43 I Outline the processes regarding screening forsanctions, PEPs and negative media Yes

43m Outline the processes for the maintenance olinternal "watchlists" Yes

44 Has the Entity defined a risk tolerance statementor similar document which defines a riskboundary around their business?

Yes

45 Does the Entity have a record retentionprocedures that comply with applicable laws? Yes

45a lf Y, what is the retention period?5 years or morgr..

46 Confirm that all responses provided in the aboveSection POLICIES & PROCEDURES arerepresentative of all the LE's branches

Yes

46a lf N. clarify which questions the difference/srelate to and the branch/es that this applies to.

46b appropriate, provide any additional informationcontext to the answers in this section.

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Wolfsberg Group Correspondent Banking Due Oiligence Questionnaire (CBDOO) V1.3

, A M,L,,,GIF &.. SA.NG:TI O N S. RIS K., A S SESSMEN T

47 )oes the Entity's AML & CTF EWRA cover thenherent risk components detailed below:

L7a ClientYeS

t7b ProductYes

17c ChannelYes

47d 3eographyYes

48 Does the Entity's AMt & CTF EWRA cover thecontrols effectiveness components detailed

below:

lUa Transaction MonitoringYeS

48b Customer Due Diligence Yes

48c )EP ldentification Yes

t8d Transaction Screening Yes

18e Name Screening against Adverse Media &Negative News

Yes

+Ef fraining and Education Yes

489 3overnance Yes I

48h Management I nformation Yes

49 Has the Entity's AML & CTF EWRA beencompleted in the last 12 months?

Yes

{9a lf N, provide the date when the last AML & CTFEWRA was comlleted.

fit

50 Does the Entity's Sanctions EWRA cover theinherent risk components detailed below:

i0a ClientYes

50b ProductYes

50c lhannelYes

50d Geography Yes

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51 Does the Entity's Sanctions EWRA cover thecontrols effectiveness componenls detailedbelow:

51 a Customer Due DiligenceYes

51 b Transaction ScreeningYes

1c Name ScreeningYes

51 d List ManagementYes

51 e Training and EducationYes

51 f SovernanceYes

519 Vlanagement lnformationYes

52 las the Entity's Sanctions EWRA been;ompleted in the last 12 months? Yes

52a N, provide the date when the last SanctionsWRA was completed.

i3 Confirm that all responses provided in the aboveSection AMt, CTF & SANCTTONS R|SKASSESSMENT are representative of all the LE'sbranches

YeS


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. KYC, CDD'and,EDD54 Does the Entity verify the identity of the

customer?Yes

55 Jo the Entity's policies and procedures set out.l/hen CDD must be completed, e.g. at the time

)f onboarding or within 30 daYsYes

56 Which of the following does the Entity gather

and retain when conducting CDD? Select all that

apply:

56a Ownership structureYes

56b ustomer identificationYes

56c Expected activity Yes

56d Natu re of business/emPloymentYes

56e )roduct usageYes

s6f Purpose and nature of relationship Yes

569 Source of funds Yes

56h Source of wealthYes

i7 Are each of the following identified:

57a Ultimate beneficial ownershiP IYes

57 a1 \re ultimate beneficial owners verified? Yes

57b Authorised signatories (where applicable) Yes

7c Key controllers Yes

57d Other relevant parties lb

58 What is the Entity's minimum (lowest) threshold

applied to beneficial ownership identification ?10%

59 )oes the due diligence process result inlustomers receiving a risk classification?

Yes

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Wolfsberg Group Correspondent Elanking Due Diligence euestionnaire (CBDDe) V1.3

50 lf Y, what faclors/criteria are used to determinethe customer's risk classification? Select all thatapply:

50a )roduct UsageYes

30b 3eographyYes

50c 3usiness Type/lndustryYes

30d -egal Entity typeYes

50e Adverse lnformationYes

30f )ther (specify)

1 )oes the Entity have a risk based approach to;creening customers for adversenedia/negative news?

Yes

2 f Y, is this at:

i2a )nboardingYes

2b (YC renewalYes

82c Irigger eventYes

B3 il/hat is the method used by the Entity to screenbr adverse media / negative news? Combination of automated and manual

54 )oes the Entity have a risk based approach toscreening customers and connected parties toletermine whether they are PEPs, or controlledly PEPs?

Yes

B5 lf Y, is this al

65a )nboardingYes tr

65b (YC renewalYes

65c l-rigger eventYes

Db /Vhat is the method used by the Entity to screen:EPS? Combination of automated and manual

67 )oes the Entity have policies, procedures andlrocesses to review and escalate potentialTatches from screening customers andlonnected parties to determine whether they are)EPs, or controlled by PEPs?

Yes

B8 foes the Entity have a process to review and;pdate customer information based on:

88a (YC renewalYes

E8b rigger eventYes

B9 )oes the Entity maintain and report metrics onlurrent and past periodic or trigger event dueJiligence reviews?

Yes

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Wolfsberg Group Correspondent [3anking Due Dilagence Questionnaire (CBDDe) V1.3

70 :rom the list below, which categories oflustomers or industries are subject to EDDend/or are restricted, or prohibited by the Entity's:CC programme?

70a \on-account customersEDD on a risk based approach

r0b \on-resident customersEDD on a risk based approach

70c Shell banksProhibited

70d VIVTS/ MSB customersEDD on a risk based approach

70e )EPsEDD on a risk based approach

70f rEP RelatedF-DD on a risk based approach

7og PEP Close AssociateEDD on a risk based approach

70h Correspondent BanksEDD on a risk based approach

70 hl lf EDD or EDD & restricted, does the EDDassessment contain the elements as set out inthe Wolfsberg Correspondent BankingPrinciples 2014?

Yes

70i Arms, defense, militaryProhibited

70j Atomic powerProhibited

zok Extractive industriesEDD on a risk based approach

0t Precious metals and stonesEDD on a risk based approach

70m Unregulated charitiesProhibited

70n Regulated charitiesEDD on a risk based approach

0o Red light business / Adult entertainmenlProhibited

op Non-Government OrganisationsEDD on a risk based approach

0q Virtual currenciesProhibited

0r MarijuanaProhibited

70s Em bassies/Consu latesEDD on a risk based approach

70t GamblingProhibited

70u ayment Service ProviderEDD on a risk based approach

70v )ther (specify)

71 lf restricted, provide details of the restriction

72 Does the Entity perform an aclclitional control orquality review on clients subject to EDD? Yes

73 Confirm that all responses provided in the aboveSection KYC, CDD and EDD are representativeof all the LE's branches

Yes

73a lf N, clarify which questions the difference/srelate to and the branch/es that this applies to



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Wolfsberg Group Conespondent Banking Due Oiligence euestionnaire (CBDDA) Vl.3

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t4 )oes the Entity have risk based policies,)rocedures and monitoring processes for thedentification and reporting of suspiciousrctivity?

Yes

5 What is the method used by the Entity tomonitor transactions for suspicious activities? Combination of automated and manual

t6 lf manual or combination selected, specify whatlype of transactions are monitored manually

Based on the triggers/alerts generated by Transaction Monitoring software, details and rationale orthe transaction is monitored manually for further investigation and regulatory reporting purpose.Dedicated staff go through the alerts, investigate and if necessary escalate for further decision.

t7 Does the Entity have regulatory requirements toreport suspicious transactions? Yes

la lf Y, does the Entity have policies, proceduresand processes to comply with suspicioustransaction reporting requirements?

Yes

r8 Does the Entity have policies, procedures andprocesses to review and escalate mattersarising from the monitoring of customertransactions and activity?

Yes

t9 Confirm that all responses provided in the aboveSection MONITORING & REPORTING arerepresentative of all the LE's branches

Yes

79a lf N, clarify which questions the difference/s.relate to and the branch/es that this applies to

/9b lf appropriate, provide any additional information/ context to the answers in this section.

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$i:i:P*vlilEN:fri:TR NSFATRENSY80 Does the Entity adhere to the Wolfsberg Group

Paym ent Transparency Standards?Yes

81 Does the Entity have policies, procedures andprocesses to [reasonably] comply with and have

controls in place to ensure compliance with:

B1 a FATF Recommendation 16Yes

1b -ocal Regulations Yes

1bl Specify the regulation Assets Laundering and Prevention ActAML RulesCentral Bank GuidelinesFIU Guidelines

1c f N, explain

82 Does the Entity have processes in place to

respond to Request For lnformation (RFls) fromother entities in a timely manner?

Yes

33 Does the Entity have controls to support theinclusion of required and accurate originatorinformation in international payment messages?

Yes

B4 Does the Entity have controls to support the

inclusion of required beneficiary informationinternational payment messages?

Yes

t5 Confirm that all responses provided in the aboveSection PAYMENT TRANSPARENCY are

representative of all the LE's branchesYes

35a f N, clarify which questions the difference/s'elate to and the branch/es that this applies to,

65b lf appropriate, provide any additional information/ context to the answers in this section. t

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Wolfsberg Group Correspondent Banking Due Diligence euestionnaire (CBDDe) Vj.3

The Wolfsberg Group 2020

l-.fiiffil [-Sffl.s,i|tlSjf; #$iifi liiiff ilifi #iiffi mi#lliliiliilf i:$XiIIi#ni1ffi fr $,fr I#l illiir*fillilllillliili86 Does the Entity have a Sanctions Policy

approved by management regardingcompliance with sanctions law applicable to theEntity, including with respect its businessconducted with, orthrough accounts held atloreign financial institutions?

Yes

87 Does the Entity have policies, procedures, orother controls reasonably designed to preventthe use of another entity's accounts or servicesin a manner causing the other entity to violatesanctions prohibitions applicable to the otherentity (including prohibitions within the otherentity's local jurisdiction)?

Yes

B8 Does the Entity have policies, procedures orother controls reasonably designed to prohibitand/or detect actions taken to evade applicablesanctions prohibitions, such as stripping, or theresubmission and/or masking, of sanctionsrelevant information in cross borderlransactions?

Yes

89 Does the Entity screen its customers, includingbeneficial ownership information collected by theEntity, during onboarding and regularlythereafter against Sanctions Lists?

Yes

90 What is the method used by the Entity?Combination of automated and manual

91 )oes the Entity screen all sanctions relevantlata, including at a minimum, entity and locationnformation, contained in cross border:ransactions against Sanctions Lists?

Yes

s2 What is the method used by the Entity?Combination of automated and manual

,3 Select the Sanctions Lists used by the Entity inits sanctions screening processes:

,3a Consolidated United Nations Security CouncilSanctions List (UN) Used for screening customers and beneficial owners anii. for flltering transactional data

93b United States Department of the Treasury'sOffice of Foreign Assets Control (OFAC) Used for screening customers and beneficial owners and for filtering transactional data

93c f,ffice of Financial Sanctions lmplementationrMT (OFSt) Used for screening customers and beneficial owners and for filtering transactional data

93d Suropean Union Consolidated List (EU)Used for screening customers and beneficial owners and for filtering transactional data

,3e Lists maintained by other G7 member countries e veePr ;{APAN,93f Other (specify)

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95 When regulatory authorities make updates totheir Sanctions list, how many business daysbefore the entity updates their active manual and/or automated screening systems against:

l5a Customer Data

Same day to 2 business days

95b fransactions

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96 Does the Entity have a physical presence, e.9.,branches, subsidiaries, or representative officeslocated in countries/regions against which UN,OFAC, OFSI, EU and G7 member countrieshave enacted comprehensive jurisdiction-based

Sanctions?

No

7 Confirm that all responses provided in the aboveSection SANCTIONS are representative of allthe LE's branches

Yes


)7b f appropriate, provide any additional information'conlext to the answers in this section.


Wolfsberg croup Correspondent Banking Due Diligence euestionneire (CBDDQ) V1.3

I1. TRAINING .& EDUCATI.ON,8 Does the Entity provide mandatory training,

which includes :

18a ldentification and reporting of transactions togovernment authorities Yes

,8b Examples of different forms of moneylaundering, terrorist financing and sanctionsviolations relevant for the types of products andservices offered

Yes

,8c lnternal policies for controlling moneylaundering, terrorist financing and sanctionsviolations

Yes

,8d New issues that occur in the market, e.9.,significant regulatory actions or new regulations Yes

)8e Conduct and CultureYes

,9 ls the above mandatory training provided to

,9a Board and Senior Committee ManagementYes

)9b 1st Line of DefenceYes

)9c 2nd Line of DefenceYes

t9d 3rd Line of DefenceYes

)9e 3rd parties to which specific FCC activities havebeen outsourced Yes b

l9f Non-employed workers(contractors/con su ltan ts) Yes

100 Does the Entity provide AML, CTF & Sanctionstraining that is targeted to specific roles,responsibilities and high risk products, servicesand activities?

Yes

101 Does the Entity provide customised training forAML. CTF and Sanctions staff? Yes

102 Confirm that all responses provided in the aboveSection TRAINING & EDUCATION arerepresentative of all the LE's branches

Yes

'102 a lf N, clarify which questions the difference/srelate to and the branch/es that this applies to.

'to2 b lf appropriate, provide any additional information/ context to the answers in this section.

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lti2l:iQt : |"TV.IASS:I}RANGE.I/0:OTMF,EIAN,GE TEST|NG103 Are the Entity's KYC processes and documents

subject to quality assurance testing? Yes

104 Does the Entity have a program wide risk basedCompliance Testing process (separate to theindependent Audit function)?

Yes

105 Confirm that all responses provided in the aboveSection QUALITY ASSURANCE /COMPLIANCE TESTING are representative ofall the LE's branches

Yes

105 a lf N, clarify which questions the difference/srelate to and the branch/es that this applies to.

105 b f appropriate, provide any additional information

'context to the answers in this section.

Wolfsberg Group Correspondent Banking Due Diligence euestionnaire (CBDDa) Vi.3

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13, AUDTT---+r_'t 06 ln addition to inspections by the government

supervisors/regulators, does the Entity have aninternal audit function, a testing function or otherindependent thircl party, or both, thal assessesFCC AML, CTF and Sanctions policies andpractices on a regular basis?

Yes

107 How often is the Entity audited on its AML, CTF& Sanctions programme by the following:

107 a lnternal Audit DepartmenlYearly

107 b External Third PartyYearly

08 Does the internal audit function or otherindependent third party cover the followingareas:

108 a AML, CTF & Sanctions policy and proceduresYes

108 b KYC / CDD / EDD and underlyingmethodologies Yes

108 c Transaction MonitoringYes

108 d Transaction Screening including for sanctionsYes

10E e \ame Screening & List ManagementYes

108 f Iraining & EducationYes

108 g TechnologyYes

108 h 3overnanceYes

108 i leporting/Metrics & Management lnformationYes

108 j Suspicious Activity Filing

{xYes

108 k nterprise Wide Risk AssessmentYes

108 I Other (specify)

109 Are adverse findings from internal & externalaudit tracked to completion and assessed foradequacy and completeness?

Yes

10 Confirm that all responses provided in the abovesection, AUDIT are representative of all the LE'sbranches

Yes

110 a lf N, clarify which questions the difference/srelate to and the branch/es that this applies to

110 b lf appropriate, provide any additional information/ context to the answers in this section.

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@ The Wolfsberg Group 2020 Page 19 CBDDQ V1-3

Wolfsberg Group Correspondent Banking Due Diligence Questionnaire (CBDDO) V1.3

laration Statement

Group Correspondent Banking Due Diligence Questionnaire 2020 (CBDDQ V1 .3)

Statemenl (To be signed by Global Head of Correspondent Banking or equivalent position holder AND Group Money Laundering Prevention Officer, Global Head ofMoney Laundering, Chief Compliance Officer, Global Head of Financial Crimes Compliance OR equivalent)

H irnalayan: tsank Lir,h ited(Financial lnstitution name) is fully committed to the fight against financial crime and makes

and regulatory obligations.

he information provided in thiswolfsberg CBDDQ will be kept current and will be u.pdated no less frequently than on an annual basis.

'he Financial lnstitution commits to file accurate sudiplemental information on a timely basis.

BhaWa,ni Gh'imire(Global Head of Correspondent Banking or equivalent), certify that I have read and understood this declaration, that ,

answers provided in this Wolfsberg CBDDQ are complete and conect to my honest belief, and that I am authorised to execute this declaration on behalf of the Financial

FrakaSh Bhahdari ' , (MLRO or equivalent), certify tha d understood this declaration, that the answers provided in thisCBDDQ are complete 2nd correct to my hohest belief, and that I am authorised to tion on behalf of the Financial lnstitution.

u (Signature & Date)

q NY a2f lq qy'1fr'7-D(Sisnature& Date) Himalavan Bank Limited

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CBDDO

Wotfsberg Group - Himalayan Bank...l"limalairan Bank Linltsd @ The Wolfsberg Group 2020 25 Has the...

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