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AML questionnaire

AML Pre-Examination Questionnaire
0%
Questions marked with an * are required Exit Survey
 
 
Please complete the following questions. The answers the firm provides assists ITA to better understand the firm's business. The firms participation helps ITA conduct the independent AML exam in a relevant, efficient and meaningful manner .
 
 
Firm Details
 
 
When was your last independent AML examination? (Enter N/A if your firm has not received a previous AML exam.)
   
 
 
 
* Who is the AML Compliance Officer?
   
 
 
When did the AML CO start?
   
 
 
* Who does the AML CO report to?
   
 
 
 
* Who is the firm's parent company?
   
 
 
Does the firm have any affiliates?
 
Yes
 
No
 
 
Who are the affiliates, if applicable?
   
 
 
* What is the parent's and/or affiliate's involvement with the BD's AML compliance program, if any?
   
 
 
Are the parent company and any affiliate relationships reflected correctly on broker check?
 
Yes
 
No
 
Other
 
 
 
 
AML WSPs
 
 
* Who is responsible for the written AML policy and procedures?
   
* Who evidences approval and how is it documented?
   
 
 
* How does the firm make the AML P&P available to employees (Select all that apply)?
 
Email
 
Internal website/Online
 
Hard copy
 
Other
 

 
 
* How often are the AML policies and procedures reviewed?
 
Monthly
 
Quarterly
 
Semi Annually
 
Annually
 
Other
 
 
 
* Does the firm require an AML attestation from employees?
 
Yes
 
No
 
 
How does the firm record the annual attestations?
   
 
 
 
* Where are the firm's AML books and records located (Select all that apply)?
 
Home office
 
Remote location (branch)
 
Other
 

 
 
 
Firm Business Details
 
 
* What types of business are conducted by the BD (Select all that apply)?
 
Brokerage
 
Direct business
 
M&A
 
Investment banking
 
Equities
 
Options
 
Fixed Income
 
Municipals
 
REIT
 
ETF
 
Mutual funds
 
Private placements
 
Structured products
 
Variable Annuity
 
Variable Life
 
Other
 

 
 
* Please select the amount of revenue on a percentage basis for each business line:
Brokerage
Direct business
M&A
Investment banking
Other
0
Values must add up to 100
 
 
Please select a revenue percentage for each product:
Equities
Options
Fixed Income
Municipals
REIT
ETF
Mutual funds
Private placements
Structured products
Variable Annuity
Variable Life
Other
0
 
 
What percentage of the firm's transactions are settled DVP/RVP?
   
 
 
 
Firm Clients
 
 
 
* What types of customers does your firm work with?
 
Individuals
 
Trusts
 
Businesses
 
Institutions
 
Other financial institutions
 
Other
 

 
 
* Approximately how many total clients does the firm have?
   
 
 
* Does your firm have any foreign clients?
 
Yes
 
No
 
 
* What percentage of the firm's customers are:
Foreign
Domestic
0
Values must add up to 100
 
 
What countries does the firm have clients in? (If applicable)
   
Which countries does the firm prohibit business in?
   
 
Does the firm have any of the following clients?
Number
* Foreign banks
* Correspondent accounts
* Politically exposed persons
* Private banking clients
 
 
AML Operations
 
 
 
Please describe your new customer on-boarding process:
   
 
 
* Are any automated systems used during the on-boarding process for AML purposes?
 
Yes
 
No
 
 
* Please list the name of the system, purpose and date of first use:
   
 
 
 
Money movement & disbursements
 
 
* Has the firm accepted cash?
 
Yes
 
No
 
 
Has a prospect or existing customer attempted to deposit cash?
 
Yes
 
No
 
 
 
* Does the firm accept checks?
 
Yes
 
No
 
 
* Does firm facilitate third party wires or checks?
 
Yes
 
No
 
 
* Does the firm accept physical stock certificates?
 
Yes
 
No
 
On average, how many of the following does the firm send/receive per month?
Number
* Incoming checks
* Outgoing checks
* Incoming wires
* Outgoing wires
* Stock certificates
* Money orders
* Cashiers checks
* Official checks
* Travelers checks
* Third party wires
* Third party checks
 
 
Monitoring
 
 
* How does the firm monitor incoming and outgoing wires?
   
 
 
* How does the firm monitor incoming and outgoing checks?
   
 
 
* How does the firm monitor internal transfers (journals from one account to another)?
   
 
 
* How does the firm monitor trading?
   
 
 
* What other activity is monitored?
   
 
 
* Please describe any automated systems used for monitoring:
   
* Has a review of the automated criteria/filters been conducted?
   
* How often and by whom, if conducted?
   
 
 
 
Suspicious Activity
 
 
* Are any SARs, details of SARs or details of suspicious activity investigations (reviews, red flags) shared with parent or affiliates?
 
Yes
 
No
 
 
Under what circumstances are SARs, details of SARs, or details of suspicious activity shared with the parent or affiliate(s)?
   
 
 
* Has the firm identified any suspicious activity since the last AML exam (or during exam period)?
 
Yes
 
No
 
 
* Did the firm share the suspicious activity or SAR details with the parent, affiliate or other firm?
   
 
 
* How does the firm document suspicious activity reviews?
   
 
 
* Did the firm file any SARs during the review period?
 
Yes
 
No
 
 
* Did the firm file any SARs during the past 5 years?
 
 
* How many SARs were filed?
   
 
 
* Where are SARs maintained?
   
* Who has access to SAR documentation/details?
   
* How is access restricted?
   
 
 
Law Enforcement / Government Lists
 
Has the firm received any:
Yes No
* Law enforcement requests?
* National securities letters (NSL)?
* Grand jury subpoenas?
 
 
Has any regulator sited any deficiences regarding AML in the past two years?
   
 
 
In brief, please describe if any of the above were received:
   
 
 
* Please describe the firm's initial OFAC screening process (the process, how often, how it is documented):
   
 
 
* Were any positive matches during the review period?
 
Yes
 
No
 
 
* Does the firm conduct ongoing OFAC screening of all clients?
 
Yes
 
No
 
 
Please describe the ongoing OFAC screening process, it's frequency and documentation, if applicable:
   
 
 
Please describe any automated systems or methods used to screen for OFAC?
   
Does the firm test the systems, if any are used?
   
Does the firm document testing conducted, if any systems are used?
   
 
 
* Please describe the firm's 314(a) screening process:
   
* Who is responsible for conducting the screening?
   
* Who has access to 314(a) data?
   
* How are the 314(a) requests secured?
   
* Did the firm have any positive matches during the exam period?
   
 
 
 
Reliance
 
 
* Does the firm rely on any other business or person to conduct AML duties including CIP, monitoring, OFAC screening etc...?
 
Yes
 
No
 
 
Please describe the AML duties handled by another party or business:
   
 
 
Does the firm have all applicable reliance agreements on file?
 
Yes
 
No
 
 
 
Training
 
 
How are employees trained with regard to AML (firm policies and procedures and industry regulations)?
   
How often does training occur?
   
How does the firm document evidence of the training?
   
Does the firm have any non-registered persons with operational duties?
   
Are non-registered operational persons trained on AML, if applicable?