GXI Anti-Money Laundering Questionnaire

This questionnaire serves as an aid to G-Xchange, Inc. (GXI) in conducting due diligence and as a tool to
comply to Bangko Sentral ng Pilipinas' (BSP) regulations. This questionnaire may be used along with GXI's
policies and will serve as a basis in performing due diligence in a manner consistent to the client's risk profile.
GXI has the responsibility to ensure adequate due diligence which includes verifying and following-up to the
documents and answers provided by its clients.

1 General Anti-Money Laundering (AML) Policies, Practices

and Procedures
Does the partner have an AML policy approved by the Board or senior committee?
1
YES NO Comment:
2 Does the policy cover:
‘Know Your Customer’ requirements?

YES NO Comment:
Screening against relevant sanction lists and lists of politically exposed persons?
If yes, please indicate all the sources and names of the databases used (e.g. OFAC, UN, etc.)

YES NO Comment:
Prevention, detection and reporting of suspicious activity/transactions?

YES NO Comment:
AML training for staff?

YES NO Comment:
Retention of AML related records pursuant to applicable law?
If yes, then for how long?

YES NO Comment:
3
Does the partner have a AML Officer or nominated officer that is responsible for coordinating and
overseeing the AML program in market on a day-to-day basis?

YES NO Name(s):
4
Does the partner have self-assessment procedures as part of its internal control environment to
assure compliance with applicable laws and internal policies and procedures?

YES NO Comment:

5
In addition to inspections by the government supervisors/regulators, does the partner have an
internal audit function or other independent third party that assesses AML practices and
procedures on an annual basis?

YES NO Comment:
6
Does the partner have a policy prohibiting accounts/relationships with shell organizations?
YES NO Comment:
7
Does the partner assure AML compliance of third parties it outsources part of its services to?
YES NO Comment

Version 4.0 Confidential and Proprietary May 2018

Page 1 of 5
 2 Agent Due Diligence
Weaknesses in the due diligence carried out on third party agents exposes G-Xchange, Inc.’s platform to a
high risk of abuse from criminals and terrorists. The controls below are minimum standards and should be
enhanced where appropriate/required.

1 Does the partner outsource any of its remittance business operations to agents and sub-agents?
Note: If “NO”, then please proceed to Section 3
YES NO
2 Provide list of agents for international remittance: name, location, type (cash-in, cash-out,
registration, KYC)
Reference to attachment:

3 Does the partner have a risk assessment process that considers:

The ownership of agents and sub-agents, including screening against applicable government lists?

YES NO Comment:.
Any information known or readily available to the Partner about the agent’s anti-money laundering
record, including information in the public domain?

YES NO Comment:.
The nature of the agent’s business and the extent to which its business presents an increased risk
for money laundering or terrorist financing?

YES NO Comment:
The nature and duration of the partner’s relationship with the agent?

YES NO Comment:
4
Does the partner have procedures that require due diligence on each new agent be performed at
the beginning of the relationship, proportionate to the risk posed by such entities?

YES NO Comment:
5 Do these procedures, as a minimum:
Identify the owners of the agents and sub-agents?

YES NO Comment:
Screen the owners against lists of sanctioned individuals and politically exposed persons?

YES NO Comment:
Evaluate, on an ongoing basis, the operations of those agents and their implementation of the AML
policies, procedures, and controls?

YES NO Comment:
6
What processes does the partner have in place to address issues if an agent poses an
unacceptable level of risk for the partner’s compliance with AML regulation?

7
Are the above processes carried out down to individual retail premise level of an agent?

YES NO Comment:
8
Do the contracts between the partner and agent grant full audit rights to the partner?

YES NO Comment:

Version 4.0 Confidential and Proprietary May 2018

Page 2 of 5
 3 Know Your Customer (KYC) / Customer Due Diligence (CDD)
Indicate which measures the partner has adopted to deter money laundering:

1
Describe the process for the identification of the customer/Beneficial Owner prior to an account
being opened/transaction taking place?

2 Does the partner collect KYC information including name, home address, date of birth and
nationality?

YES NO Comment:
3
Does the partner periodically update the KYC profiles of the customer/ Beneficial Owner?

YES NO Comment:
4
Does the partner take steps to understand the normal and expected transactions of the customer
/Beneficial Owner and obtain information in relation to the purpose and intended nature of the
envisaged business relationship?

YES NO Comment:
5
Is the identity of customers/Beneficial Owners required AND verified for all one off transactions?

YES NO Comment:

6 Describe the process for verifying identity documents and storing evidence of KYC both when
customer is physical present or not

7 Describe the process for performing screening of customers/ Beneficial Owners against lists of
sanctioned individuals and politically exposed persons.

4 Suspicious Activity Reporting and Transaction Monitoring

1 Does the partner have an effective transaction monitoring program covering domestic and
international transfers by both account holders and non-account holders for suspicious or unusual
activities?

YES NO Comment:
2 Is a clear reporting line in place for staff and agents to report knowledge or suspicion of money
laundering to the AML Officer/nominated officer?

YES NO Comment:
3
Does the partner have procedures to ensure the legal obligation to report suspicions of money
laundering to the authorities is met in a voluntary and timely manner?

YES NO Comment:.
4
Are procedures in place to ensure any mandatory transaction reporting requirements in local
legislation are adhered to?

YES NO Comment:
Version 4.0 Confidential and Proprietary May 2018
Page 3 of 5
 5 AML Training and Awareness
1
Does the partner provide regular anti-money laundering awareness training to its employees and
agents (down to individual outlets) that includes identification requirements, examples of different
forms of money laundering involving the money transfer service, internal policies and procedures
to prevent money laundering as well as the process to report suspicious transactions?

YES NO Comment:
2
Does the partner retain records of its training sessions including the dates and content of the
training, as well as the results of knowledge tests?

YES NO Comment:
3
Does the partner have procedures to communicate new or revised anti-money laundering laws,
rules and regulations to the partner’s employees and agents?

YES NO Comment:

6 Record Retention
1
Does the partner have record retention procedures (i.e. safekeeping of KYC records and transaction
records) which are in lined with applicable laws and regulations?
If yes, then for how long?
YES NO Comment:
2 Do transaction records enable the transaction to be reproduced by including the amount, name and
address of originator, name of beneficiary, unique identifier and currency?

YES NO Comment:
3 Is the above information submitted with each transaction?

YES NO Comment:
4
Are the above records stored securely and readily available to the nominated AML officer?

YES NO Comment:

7 Additional Comments
Any further information to be supplied to support the assessment of the partner’s compliance with all legal &
regulatory requirements:

Comments:

Version 4.0 Confidential and Proprietary May 2018

Page 4 of 5
 8 Customer Declaration

The undersigned based on his/her best knowledge and belief, certifies that the above questions were
answered considering the existing internal controls of the subject institution, and further presents an accurate
representation of the existing state of the institution’s anti-money laundering and counter-terrorist financing
internal controls and financial service activities.

COMPLETED BY

NAME/SIGNATURE :
TITLE :
EMAIL ADDRESS :
DATE :

9 Required Documents
Please provide us with the following documents together with the signed and completed Anti-Money
Laundering Questionnaire.

1. Proof of Legal Existence

Certificate of Registration showing the partners’: YES NO
 Legal name
 Business Address
 Registration Number
2. License granted by relevant regulatory body(ies) YES NO
and/or government authority(ies) authorizing
your entity to entity to engage in cross border money
transfer
3. Articles of Incorporation/Articles of Association YES NO
4. Latest General Information Sheet or other similar YES NO
constitutional documentation stating:
 Business Activity(ies)
 Names of Directors
5. Business Permit YES NO
6. Proof of Authority or Board Resolution or
Secretary’s Certificate showing the list of the person(s)
representing your entity towards GCash YES NO
 Authorized Signatory Form showing the
list of the person(s) in question (g) YES NO
 Identification Documents (National ID, Passport)
of the person(s) in question (g) YES NO
7. Recently Audited Annual Report YES NO
8. AML Policy YES NO

Version 4.0 Confidential and Proprietary May 2018

Page 5 of 5