bdo aml/kyc questionnaire

AML/KYC QUESTIONNAIRE
The AML / KYC questionnaire provides an overview of BDO Unibank, Inc. and its subsidiaries Anti-Money
Laundering and Terrorist Financing Prevention policies and practices compliant with relevant Laws, Bangko
Sentral ng Pilipinas (BSP) and Anti-Money Laundering Council (AMLC) guidelines, as well as its due diligence
requirements associated with the provision of correspondent banking services in conducting international
business.
INSTITUTIONAL INFORMATION
Name of Institution
Country of Incorporation
Registered Office
Corporate Legal Form
SWIFT Code
Corporate Website
Name of Registration Body
Registration / License No.
BDO Unibank, Inc.
Philippines
BDO Corporate Center, 7899 Makati Avenue,
Makati City, 0726 Philippines
BDO is a publicly listed stock corporation.
BNORPHMM
www.bdo.com.ph
Securities and Exchange Commission (SEC) &
Bangko Sentral ng Pilipinas (BSP)
SEC Registered (Registry No. 34001) / Banking license
granted by the BSP on 05 August 1996 to operate as an
Expanded Commercial Bank
Date of Incorporation 16 August 1967
Supervising Regulatory Body
External Auditor
Principal Activities
Bangko Sentral ng Pilipinas (BSP) &
Anti-Money Laundering Council (AMLC)
Punongbayan & Araullo, a member firm within Grant
Thornton International Ltd.
BDO Unibank, Inc. is a full-service universal bank with
various business units that focus and service diverse
customer segments like individual, corporation and
banks.
Please refer to the BDO website.
List of Domestic / Foreign Branches, Subsidiaries &
Affiliates
Please refer to the BDO website.
https://www.bdo.com.ph/about-bdo/corporateprofile#corporate_profile
https://www.bdo.com.ph/about-bdo/corporateprofile#corporate_profile

OWNERSHIP AND MANAGEMENT INFORMATION
Stock Exchange Listing
Ownership Structure
Management Structure
Philippine Stock Exchange (PSE), under the trading
name of BDO Unibank, Inc. & BDO as the stock code.
Please refer to the BDO website.
https://www.bdo.com.ph/corporate-governance/ownership
Please refer to the BDO website.
List of Directors:
https://www.bdo.com.ph/corporate-governance/board-andshareholder-matters
Principal Officers:
https://www.bdo.com.ph/corporate-governance/ownership
then click Annual Stockholder Meeting (DIS)
Anti-Money Laundering Questionnaire
I. General AML Policies, Practices and Procedures: Yes No
1. Is the AML compliance program approved by the FI’s board or a senior committee
2. Does the FI have a legal and regulatory compliance program that includes a designated
officer that is responsible for coordinating and overseeing the AML framework
3. Has the FI developed written policies documenting the processes that they have in place
to prevent, detect and report suspicious transactions
4. In addition to inspections by the government supervisors/regulators, does the FI client
have an internal audit function or other independent third party that assesses AML
policies and practices on a regular basis
5. Does the FI have a policy prohibiting accounts/relationships with shell banks (A shell
bank is defined as a bank incorporated in a jurisdiction in which it has no physical
presence and which is unaffiliated with a regulated financial group.)
6. Does the FI have policies to reasonably ensure that they will not conduct transactions
with or on behalf of shell banks through any of its accounts or products
7. Does the FI have policies covering relationships with Politically Exposed Persons
(PEP’s), their family and close associates
8. Does the FI have record retention procedures that comply with applicable law
9. Are the FI’s AML policies and practices being applied to all branches and subsidiaries of
the FI both in the home country and in locations outside of that jurisdiction
Our policy applies to all local and foreign branches and subsidiaries of BDO. Our foreign
branches and subsidiaries abroad also comply with the AML laws, rules and regulations
of their respective host countries/jurisdictions.

10. Is money laundering and terrorist financing considered a crime in you country
11. Has your country established laws designed to prevent money laundering and terrorist
financing
12. If ‘Yes’ to Question 11, please indicate the official name of the law which regulates AML
procedure in your country and the date on which this law and subsequent amendments,
if any, were passed / gazetted.
1. Republic Act (R.A.) No. 9160: The Anti-Money Laundering Act of 2001 with the following
amendments:
a. R.A. No 9194: An Act Amending Republic Act No. 9160 (effective 2003)
b. R.A. 10167: An Act to Further Strengthen the Anti-Money Laundering Law
(took effect on 06 July 2012)
c. R.A. 10365: An Act Further Strengthening the Anti-Money Laundering Law
(effective on 19 April 2013)
2. R.A. 10168: The Terrorism Financing Prevention and Suppression Act of 2012
(took effect on 05 July 2012)
3. BSP Circular No. 706: Updated Anti-Money Laundering Rules and Regulations
(took effect on 05 January 2011)
13. Is your institution subject to such laws designed to prevent money laundering and
terrorist financing
14. In case of conflict between your Home Country AML/CFT laws and / or regulations and
the local laws and / or regulations in the foreign jurisdiction where you have branches or
subsidiaries, do you apply the highest standard
15. Are the FI’s AML policies and procedures according to local laws, rules, standards and
benchmark against international standards
16. Does the FI have a policy prohibiting anonymous accounts
17. How long are records kept
All transactions records are preserved for at least five (5) years from the dates of
transactions. For closed accounts, client identification, account files and business
correspondences are maintained for at least five (5) years from the dates when
they were closed.
18. Is implementation of AML policies and procedures consistently updated wherever there
are new laws and regulations
19. Has the FI been cited by your regulatory agency for any violation of AML laws, rules or
regulations in the past 5 years

II. Risk Assessment Yes No
20. Does the FI have a risk-based assessment of its client base and their transactions
21. Does the FI determine the appropriate level of enhanced due diligence necessary for
those categories of clients and transactions that the FI has reason to believe
pose a heightened risk of illicit activities at or through the FI
III. Know Your Client, Due Diligence and Enhanced Due Diligence Yes No
22. Has the FI implemented processes for the identification of those clients on whose behalf
it maintains or operates accounts or conducts transactions
23. Does the FI have a requirement to collect information regarding its clients’ business
activities
24. Does the FI assess its FI clients’ AML policies or practices
25. Does the FI have a process to review and, where appropriate, update client information
relating to high risk client information
26. Does the FI have procedures to establish a record for each new client noting their
respective identification documents and ‘Know Your Client’ information
27. Does the FI complete a risk-based assessment to understand the normal and expected
transactions of its clients
28. Does the FI take steps to understand the normal and expected transactions of its clients
based on its risk assessment of its clients
29. Does the FI require the presentation of identification documents issued by official
authority
30. Does the FI provide services to “walk – in” clients
31. If ‘Yes’ to Question 30, does your institution identify them
We entertain walk-in clients but before we start any relationship with them, we
establish their true identity through proper KYC.
32. Does the FI follow FATF recommendations on money laundering and terrorist financing
33. Does the FI provide services to Offshore Banks, Internet Banking based institutions or
banks located in high risk areas as highlighted by FATF
34. Does the FI identify and verify the transactions related to persons / entities suspected of
ML / TF, comprised in official lists of appropriate authorities
35. Does the FI have a process to review and, where appropriate, update client information
relating to high risk client information
36. Does the FI identify and verify the transactions related to persons / entities suspected of
ML / TF

37. Does the FI ensure that effective anti-money laundering and counter-terrorism controls
are in place on new technologies and when dealing in non-face to face interactions or
through intermediaries
38. Does your compliance program include establishing policies, procedures and processes
for managing Economic & Trade Sanctions
If ‘Yes’ please indicate the Sanctions program(s) incorporated in your compliance
program:
OFAC, United Nations Security Council and FATF
39. Do you screen your clients and transactions including telegraphic transfer against a
particular Sanctions program
If ‘Yes’, please indicate the Sanctions program(s) used:
OFAC and United Nations Security Council
40. How frequent does the FI screen its existing client database
Daily and when there are new accounts opened.
41. Do you include originator information with outgoing wire transfer
42. If ‘Yes’ to Question 41, are you required by your local regulator to do so
IV. Reportable Transactions and Prevention and Detection of Transactions with
Illegally Obtained Funds
43. Does the FI have policies or practices for the identification and reporting of transactions
that are required to be reported to the authorities
44. Is the FI mandated to report transactions above a certain thresholds
45. If ‘Yes’ to Question 44, does the FI have procedures to identify transactions structured to
avoid such obligations
46. Does the FI have a monitoring program for unusual and potentially suspicious activity
that covers funds transfers and monetary instruments such as travelers checks, money
orders, etc
47. Does the FI ensure the confidentiality of Suspicious Transaction Report (STR) filings or
any information that would reveal the existence of a STR
Yes
No
V. Correspondent Banking Relationship Yes No
48. Does the FI have policies to reasonably ensure that it only operates with correspondent
banks that possess licenses to operate in their countries of origin
49. Does the FI allow direct use of the correspondent account by third parties to transact
business on their behalf (Payable-through accounts)
50. Does the FI have a standard AML / KYC questionnaire that is provided to correspondent
banks

VII. AML Training Yes No
51. Does the FI provide AML training to relevant employees that includes:
Identification and reporting of transactions that must be reported to government
authorities.
Examples of different forms of money laundering involving the FI’s products and
services.
Internal policies to prevent money laundering.
52. Does the FI retain records of its training sessions including attendance records and
relevant training materials used
53. Does the FI communicate new AML related laws or changes to existing AML related
policies or practices to relevant employees
54. Does the FI employ third parties to carry out some of the functions of the FI
55. If the answer to question 54 is yes, does the FI provide AML training to relevant third
parties that includes:
Identification and reporting of transactions that must be reported to government
authorities.
Examples of different forms of money laundering involving the FI’s products and
services.
Internal policies to prevent money laundering.
The Bank outsources some of its functions except those that are inherently bank
functions (e.g. Deposit related operation). The Bank however does not provide
AML training to these relevant agents. If these service providers are covered
institutions as defined under the Anti-Money Laundering Act, as amended, they
are mandated to conduct their own AML Training.
VIII. Contact Details Yes No
56 Has the FI appointed a Compliance Officer for the AML / KYC program
57 If yes, please give the name and title of Compliance Officer responsible for the AML /
KYC program and his / her contact details for future references.
Name:
Title:
E-mail:
Address:
Phone No: +63 2 878-4803
Fax No: +63 2 878-4205
Rebecca S. Torres
Senior Vice President and Chief Compliance Officer
torres.becky@bdo.com.ph
14 th Floor, BDO North Tower, BDO Corporate Center
7899 Makati Avenue, Makati City, 0726 Philippines
Signature: _______________________________
Date: 04 July 2013

CERTIFICATION
I, REBECCA S. TORRES, Senior Vice President and Chief Compliance Officer of
BDO Unibank, Inc., do hereby certify the following:
• That the answers and statements made in our AML / KYC Questionnaire are
complete, accurate to the best of our knowledge and reflective of our Anti-
Money Laundering & Know Your Client policies, procedures and program.
• That all Officers and Staff of our bank are aware of these policies, procedures
and program and there is an adequate compliance oversight process in place.
• That we also require our correspondent banks and tie-ups with which we do
business maintain procedures for such purpose.
• That I am the duly authorized officer of BDO Unibank, Inc. to complete and
execute the AML KYC Questionnaire
REBECCA S. TORRES
SVP and Chief Compliance Officer