Filing of 2015 Annual Statements

March 23, 2016 INSURANCE CIRCULAR LETTER NO. 017-16 TO : All Mutual Benefit Associations (MBAs) Authorized to Do Business in the Philippines SUBJECT : Filing of 2015 Annual Statements In connection with the filing of the 2015 Annual Statements, the following guidelines are hereby issued: 1. Submission of three (3) sets yellow Annual Statement of MBAs as of December 31, 2015 shall be signed and sworn to by the president, chief operating officer/general manager, secretary, treasurer, actuary and chief accountant and shall be on legal size bond paper (8 1/2 x 14 inches), using either the Times New Roman font size #12 or Arial font size #10 printed at 100 percent normal size; 2. The Annual Statement should be "Soft Cover Binding", permanent adhesive; 3. Annex "A" is the updated list of the required documents and other schedules which shall form part as attachments in the submission of Annual Statements. THIS MUST BE SUBMITTED IN SEPARATE FOLDER; 4. Annex "B" is the Anti-Money Laundering Compliance Form, which MUST BE COMPLETELY ACCOMPLISHED. 5. The exact formats, columnar headings and footnote instructions found in every page of the blank forms of the prescribed Annual Statement including those required formats attached to Annex "A" shall be STRICTLY OBSERVED; 6. Any Annual Statement not in accordance with the required format and with missing data/information and incomplete attachments SHALL NOT BE ACCEPTED. HTcADC Please file your 2015 Annual Statements on or before April 30, 2016 to avoid penalty . (SGD.) EMMANUEL F. DOOC Insurance Commissioner ANNEX A NAME OF COMPANY: _____________________________________ LIST OF DOCUMENTS TO BE SUBMITTED TO FORM PART OF THE ANNUAL STATEMENTS OF MUTUAL BENEFIT ASSOCIATIONS For the Year Ended December 31, 2015 A. To be Submitted to Life/MBAs/Trust Division (FED II): _____ 1. 2015 Audited Financial Statements with comparative figures for 2014, signed by an external auditor accredited by this Commission (a well-binded complete set of Audited Financial Statements). _____ 2. Adjusted Trial Balance signed by the Chief Accountant. _____ 3. Soft copy of the 2015 Annual Statement (in USB). _____ 4. Reconciliation Statement of the Audited Financial Statement versus The Annual Statement figures. _____ 5. Reconciliation of figures/accounts in the Adjusted Trial Balance (breakdown/groupings) to tally with the figures/accounts in the Annual Statement. _____ 6. List of current members of board of directors/trustees, independent directors/trustees and their respective addresses, positions and also the chairman and members of Audit, Remuneration and Nomination committees. _____ 7. 2015 General Information Sheet filed with SEC. _____ 8. Minutes of meetings of the board and executive committees, including copy of board resolutions made during the year. _____ 9. Accredited actuary's certification on actuarial and all related accounts (e.g., reserves, certificate/policy loans, net premiums due and uncollected, policy and contract claims payable, etc.). _____ 10. Certification of the association's comptroller or any responsible officer with the rank of at least Vice President for the account Members' Equity Value, Certificate/Policy and Other Loans, Premiums Contributions Due & Uncollected, Unremitted Premiums/Contributions, Members Deposit. _____ 11. Schedules of Claims Payable on Basic Contingent Benefit/Optional Benefits as of December 31, 2015 and of all claims filed for the 1st quarter of 2016. _____ 12. Schedule showing balance sheet items in foreign currency, if any, and their peso equivalent, including a sub-schedule showing the currency breakdown in case an account consists of multiple currencies. _____ 13. Confirmation of sales of investments in Bonds and Treasury Bills, together with Statement of Securities Account of BTr-ROSS as of year-end. _____ 14. Certification from the custodian bank of dollar-denominated Bonds as of year-end. _____ 15. Schedule of dollar denominated bonds using the attached MBA Required Format No. 2. _____ 16. Certification from Phil. Depository & Trust Co. for the scriptless stock certificates as of year-end. _____ 17. Detailed schedules, together with supporting documents, of all investments and other asset accounts. _____ 18. Breakdown/Computation/Schedule of of Fluctuation Reserve Bonds/Stocks and Revaluation Reserve-Real Estate as reported in the Annual Statement. _____ 19. Breakdown/Computation/Schedule of Unrealized Gain/Loss Bonds/Stocks that are closed to Retained Earnings. _____ 20. Detailed schedules with supporting documents on Mortgage Loans, Guaranteed Loans, Membership Certificate Loans, Policy Loans, Collateral Loans and Other Loans accounts. _____ 21. Bank statements/passbooks of all current, savings and time deposit accounts as of December 31, 2015 and January 2016, together with the pertinent bank reconciliation statements. _____ 22. Detailed schedule of undeposited collections, if any, showing in columns the official receipts number, date, date deposited, name of depository bank and to be supported with Official Receipts and Validated Deposit Slips. _____ 23. Detailed schedule of deposit in transit showing in columns the official receipts number, date, date deposited, name of depository bank and to be supported with Official Receipts and Validated Deposit Slips. _____ 24. Detailed Schedule of EDP for the last five (5) years together with the sales invoices and official receipts to support purchases of EDP Equipment during the year. _____ 25. Official receipts to support payments of Real Estate Tax during the year. _____ 26. Schedule of Reinsurance Recoverable and Due to Reinsurers as of year-end, if any, using the attached MBA Required Format No. 6. _____ 27. Certification of receivables from government agencies/ government-owned and controlled corporations. _____ 28. Seriatim list (in soft copy) of all the members indicating therein the certificate number, effectivity date of membership, total actual contributions and equity values as of year-end (Required Format No. 3). _____ 29. Summary of in-force certificates and policies by plan of insurance as of December 31, 2015 using the attached MBA-Required Format No. 1. _____ 30. Soft copy of Schedule of Receivables, Claims using MBA-Required Format Nos. 4 & 5. B. To be Submitted to the Statistics & Research Division: _____ 1. 2015 Audited Financial Statements with comparative figures for 2014, signed by an external auditor accredited by this Commission. _____ 2. Adjusted Trial Balance signed by the Chief Accountant. _____ 3. Statement of Income and Retained Earnings Exhibit 2. _____ 4. Computation of the Risk Based Capital Ratio of the Association. _____ 5. Soft copy of the 2015 Annual Statement and attachments (in USB) _____ 6. Reconciliation Statement of the Audited Financial Statement versus The Annual Statement figures. _____ 7. Reconciliation of figures/accounts in the Adjusted Trial Balance (breakdown/groupings) to tally with the figures/accounts in the Annual Statement. _____ 8. Extra copy of Page 1. _____ 9. List of current members of board of directors and trustees, independent directors/trustees and their respective addresses, positions and also the chairman and members of Audit, Remuneration and Nomination committees. _____ 10. Accredited actuary's certification on actuarial and other related accounts (e.g., reserves, certificate/policy loans, net premiums due and uncollected, policy and contract claims payable, etc.). _____ 11. Summary of in-force certificates and policies by plan of insurance as of December 31, 2015 using the attached MBA-Required Format No. 1. _____ 12. For companies with Micro-Insurance business: _____ a. Performance Standard (SEGURO); and _____ b. Soft Copy of the following: _____ Production: Schedule showing separately in columns the name of the assured, policy number, certificate number, sum assured and premium (per product line). _____ Collections: Schedule showing separately in columns the name of the assured, policy number, certificate number, sum assured, premium, and amount collected, date and number of official receipt. _____ Claims Paid: Schedule showing separately in columns the name of assured/claimant, claim no., date filed, policy number, sum insured, date of loss, amount of loss, nature of claim, date paid and voucher number. C. To be Submitted to the Microinsurance Division Soft copy of the following to be submitted in USB: _____ 1. 2015 Annual Statement. _____ 2. Adjusted Trial Balance as of December 31, 2015. _____ 3. Income Statement of the year ended December 31, 2015. _____ 4. List of current members of board of directors, independent directors, their respective addresses, positions and also the chairman and members of Audit, Remuneration and Nomination committees. _____ 5. Copy of the Schedule on Benefits Payable (Format #5, New Format) _____ 6. Schedule of Claims paid/denied during the year (Format No. 7). _____ 7. Copy of MBAs Required Format No. 1 & 4. Submitted by: __________________________ Received by: __________________________ Date: __________________________ MBA-Required Format No. 1 MBA-Required Format No. 2 MBA Required Format No. #3 MBA Required Format No. 4 MBA Required Formal No. #5 MBA Required Format No.# 6 MBA Required Format No. #7 ANNEX B Anti-Money Laundering Compliance Form _____________________ Name of company Practices and Acts Required under AMLA, Yes No Explanation/Reason for Its IRR and Operating Manual Non/Compliance I. ADOPTION OF THE MANUAL Anti-Money Laundering Operating Manual 1 Do you have an Anti-Money Laundering (AML) ______ ______ __________________ Operating Manual? 2 Did you submit your AML Operating Manual to the ______ ______ __________________ Insurance Commission? 3 Is your AML Operating Manual being followed by ______ ______ __________________ your personnel in your day-to-day operations? II. CUSTOMER DUE DILIGENCE OR KNOW-YOUR- CUSTOMER RULE A. Questions Applying to All Covered Institutions Regulated by the Insurance Commission 4 Do you obtain the following information from your ______ ______ __________________ customer (i.e., client/member)? 4.1 Complete name(s) used? ______ ______ __________________ 4.2 Present address or residence in the ______ ______ __________________ Philippines, or abroad, if customer is a non-resident? 4.3 Residence telephone numbers? ______ ______ __________________ 4.4 Permanent address for both resident and ______ ______ __________________ non-resident? 4.5 Mailing address, if different from 4.2 and 4.4? ______ ______ __________________ 4.6 Birth date and birth place? ______ ______ __________________ 4.7 Nationality? ______ ______ __________________ 4.8 Nature of work or occupation of the customer ______ ______ __________________ e.g., attorney, cashier, physician (do not use non-descript terms such as businessman, employee, merchant, store owner (unless name of store is provided)? 4.9 Name of employer, if employed, and the ______ ______ __________________ complete address and telephone numbers of the employer? 4.1 Nature of self-employment or business, or ______ ______ __________________ name of the single proprietorship and its complete address and telephone numbers? 4.11 Customer's Tax Identification Number? ______ ______ __________________ 4.12 Customer's Social Security Numbers or ______ ______ __________________ Government Service Insurance System Numbers? 4.13 Sources of funds? ______ ______ __________________ 4.14 Complete name, address and contact ______ ______ __________________ information of beneficial owner? 5 In addition to No. 4, do you require the following ______ ______ __________________ information in cases where the applicants are acting in a representative capacity? 5.1 Legal capacity of the customer? ______ ______ __________________ 5.2 Identity of the principal owner or beneficiary, ______ ______ __________________ including information from 4.1 to 4.14? 5.3 If customer is a legal entity such as a ______ ______ __________________ corporation, the identity of the person authorized, including information from 4.1 to 4.9? 5.4 Is there a designated officer or staff ______ ______ __________________ authorized to obtain from the customers the abovementioned information or documents relevant thereto? If yes, specify below the rank, office or designation: ___________________________________ B. Questions on Documentations B.1 Individuals as Clients 6 For purposes of No. 4, do you require from ______ ______ __________________ the customer the original copy of any of the following identification documents before opening of an account? 6.1 Philippine passport or passport issued by ______ ______ __________________ a foreign government? 6.2 Driver's license? ______ ______ __________________ 6.3 Any official original identity card issued by ______ ______ __________________ the National Government of the Republic of the Philippines, its political subdivisions or instrumentalities, or government-owned and controlled corporations? 7 Do you obtain from the customer prior to the opening ______ ______ __________________ of an account the following: 7.1 Notarized special authorizations, for the ______ ______ __________________ representatives? 7.2 Trust agreement, if acting as a trustee? ______ ______ __________________ 7.3 Other pertinent and reasonable documents ______ ______ __________________ deemed necessary under the circumstances? Specify below the documents, if applicable. ___________________________________ ___________________________________ ___________________________________ B.2 Corporate/Partnership/Single Proprietors as Clients 8 Do you obtain from your client copies of the ______ ______ __________________ following documents: 8.1 Certificate of registration issued by the ______ ______ __________________ Securities and Exchange Commission (SEC), for corporation or partnership, or by the Department of Trade and Industry, for single proprietorship, including the Articles of Incorporation or Partnership? 8.2 Latest General Information Sheet (GIS) and ______ ______ __________________ other documents such as clearance from the SEC that the company is active and compliant with reportorial requirements? 8.3 Appropriate board resolution? ______ ______ __________________ 8.4 For customers who are non-residents, do ______ ______ __________________ you require that the documents under No. 7 be duly authenticated by the Philippine Embassy or Consulate where said companies are located? C. Questions on Prohibited Accounts 9 Do you maintain accounts only in the names of the ______ ______ __________________ policyholders? 10 Do you allow the opening, keeping or maintaining ______ ______ __________________ any of the following accounts: 10.1 Anonymous accounts? ______ ______ __________________ 10.2 Fictitious names accounts? ______ ______ __________________ 10.3 Incorrect name accounts? ______ ______ __________________ 10.4 Accounts similar to the foregoing ______ ______ __________________ 11 Have you refused opening of accounts under ______ ______ __________________ any of the following circumstances: 11.1 Those covered under No. 10 hereof? ______ ______ __________________ 11.2 If customer fails to provide the requested ______ ______ __________________ evidence of identity? 11.3 If contrary to the established policies and ______ ______ __________________ procedures of the covered institution? Specify below said policy or procedure, if applicable. _________________________________ _________________________________ _________________________________ 12 Have you closed prohibited accounts after the ______ ______ __________________ adoption of the AMLA, as amended, and its Implementing Rules and Regulations? 13 How many prohibited accounts have been ______ ______ __________________ closed? D. Questions on Accounts without Face-to-Face Contacts 14 Are your prospective clients interviewed personally? ______ ______ __________________ 15 Do you allow the opening of accounts thru any of ______ ______ __________________ the following circumstances: 15.1 Internet? ______ ______ __________________ 15.2 Post? ______ ______ __________________ 15.3 Telephone? ______ ______ __________________ 15.4 Other instances such as: ____________ ______ ______ __________________ ________________________________ 16 Do you have policies and procedures specifying ______ ______ __________________ reliance on an intermediary or third party for your Know-Your-Customer (KYC) or customer due diligence requirements? 17 Is the intermediary or third party referred to in ______ ______ __________________ No. 16 a covered institution under the AMLA, as amended, or as defined and identified by foreign jurisdiction in so far as covered institutions in their respective jurisdictions are concerned? 18 Where reliance is permitted, do you undertake ______ ______ __________________ the following: 18.1 Immediately take adequate steps to ______ ______ __________________ satisfy yourself that copies of identification data and other relevant documentation relating to the customer due diligence requirements are available from the intermediaries or third parties upon request without delay? 18.2 Satisfy yourself that the intermediaries or ______ ______ __________________ third parties are regulated and supervised, and have measures in place to comply with customer due diligence requirements? 18.3 Ensure that the customer identification ______ ______ __________________ program of the intermediaries or third party is similar to or equivalent to your customer identification program? 18.4 That the ultimate responsibility for customer ______ ______ __________________ and/or beneficial owner identification and verification remains with you? E. Questions on New Technologies 19 Do you pay special attention to any money ______ ______ __________________ laundering threats that may arise from new or developing technologies that might favor anonymity? 20 Do you take measures to prevent money ______ ______ __________________ laundering schemes? F. Policy Not to Transact 21 Do you inform your clients of your explicit ______ ______ __________________ policy that business transactions will not be conducted if they fail to provide sufficient evidence of their identity? G. Renewal or Identification 22 Do you regularly update or renew identification ______ ______ __________________ of your clients particularly under any of the following situations: 22.1 Changes of the applicable information ______ ______ __________________ required under Nos. 4 to 8, except No. 6? 22.2 When there is doubt as to the identity of ______ ______ __________________ your client, beneficial owner, or the principal it purports to represent? 22.3 Whenever necessary pursuant to your ______ ______ __________________ established policies and procedure? H. Old Accounts 23 Have you taken actions to clean out old accounts? ______ ______ __________________ 24 What actions have you taken to clean out old ______ ______ __________________ accounts? ________________________________________ ________________________________________ I. Simplified or Reduced Customer Due Diligence 25 Do you apply simplified or reduced customer due ______ ______ __________________ diligence to the following customers: 25.1 Financial institutions where they are ______ ______ __________________ subject to requirements to combat money laundering and the financing of terrorism consistent with the Recommendations of the Financial Action Task Force (FATF) and are supervised for compliance with those controls? 25.2 Public companies that are subject to ______ ______ __________________ regulatory disclosure requirements? 25.3 Government institutions and its ______ ______ __________________ instrumentalities? J. Verification J.1 Accounts without Face-to-Face Contacts 26 Do you ensure that the customer identification ______ ______ __________________ procedures for non-face-to-face verification be as stringent as those for face-to-face verification? 27 Do you have the following as risk mitigating ______ ______ __________________ measures: 27.1 Certification by appropriate authorities ______ ______ __________________ and professionals of the documents provided? 27.2 Requisition of additional documents to ______ ______ __________________ complement those which are required for face-to-face customers? 27.3 Independent contact with the customer? ______ ______ __________________ 27.4 Third party introduction, e.g., by an ______ ______ __________________ intermediary? 27.5 Requiring the first payment to be carried ______ ______ __________________ out through an account in the customer's name with a bank subject to similar customer due diligence standards? 28 Do you require that documents under Nos. 7 and ______ ______ __________________ 8 be authenticated by the Philippine Embassy or Consulate for those non-residents opening an account without face-to-face contact? J.2 Corporate Accounts 29 Before establishing business relationship, do ______ ______ __________________ you ensure that corporate client or other kind of business applicant has not been, or is not in the process of being dissolved, struck off, wound-up or terminated? J.3 Trust, Nominee and Fiduciary Accounts 30 Do you determine whether your customer is ______ ______ __________________ acting in behalf of another person as trustee, nominee or agent? 31 Do you establish the identities of the agent/s and ______ ______ __________________ the authorized signatories, as well as the nature of their trustees or nominee capacity and duties? 32 In case you suspect that the trustee, nominee or ______ ______ __________________ agent is only a dummy, do you undertake further verification to verify the business relationship between the parties? 33 In case satisfactory evidence of the beneficial ______ ______ __________________ owners cannot be obtained, do you proceed to: 33.1 Conduct or continue transacting with the ______ ______ __________________ client? 33.2 Stop transacting with such account? ______ ______ __________________ 34 For purposes of 33.1, do you undertake the ______ ______ __________________ following: 34.1 Record any misgivings? ______ ______ __________________ 34.2 Monitors said account? ______ ______ __________________ 35 Do you conduct reasonable inquiries on the ______ ______ __________________ transactions whenever these transactions pass through accounts opened by a law firm or accountants that give cause for concern? 36 Do you report to AMLC transactions under Nos. ______ ______ __________________ 33 and 34, pursuant to the provisions of the AMLA, as amended, and your established policies and procedures, if you have a basis for reporting under the provisions of the AMLA, as amended? J.4 High Risk Customers 37 Do you give special attention to business ______ ______ __________________ relationships and transactions with persons, including companies and financial institutions, from countries which do not or insufficiently apply the FATF Recommendations? 38 Do you ensure that the principles applicable to ______ ______ __________________ your institution are also applied to your branches and majority owned subsidiaries located abroad, especially in countries which do not or insufficiently apply the anti-money laundering measures implemented in the Philippines? 39 Do you consider costumers from countries which ______ ______ __________________ do not have or insufficiently apply anti-money laundering measures as high risk customers? 40 Do you establish the source of wealth of higher ______ ______ __________________ risk customers? 41 Are decisions on business relations with higher ______ ______ __________________ risk customers taken by your senior management? III. MONITORING, RECORDING AND REPORTING A. Monitoring 42 Do you conduct monitoring of the following ______ ______ __________________ business relationships and transactions: 42.1 Transactions involving trust, nominee and ______ ______ __________________ fiduciary accounts? 42.2 Transactions involving shell companies ______ ______ __________________ which have been allowed to transact after undertaking necessary verifications? 42.3 Complex, unusual large transactions, or ______ ______ __________________ unusual patterns of transactions? 42.4 Business relationships and transactions ______ ______ __________________ with persons, whether natural or juridical, from countries which do not or insufficiently apply the FATF Recommendations? 42.5 Transactions which are suspected to be ______ ______ __________________ made by a person included in the list of suspected terrorists, or terrorist organizations that may be furnished by the AMLC or by any other law enforcement agency or pursuant to internal policies and procedures? 42.6 Transactions made by persons, whether ______ ______ __________________ individuals or corporate, who had been subjected to further verifications but nonetheless required to be monitored by the covered institution as part of its enhanced KYC application or AMLA compliance procedure? 42.7 Any other transaction which you may deem ______ ______ __________________ necessary to be monitored based on surrounding facts or circumstances and your established policies and procedure? 43 Is there a designated specific officer or staff ______ ______ __________________ authorized to monitor any of the transactions referred to above? Specify the rank, office or designation: ____________________________________ ____________________________________ B. Recordkeeping 44 Do you keep and maintain documentations on the ______ ______ __________________ following: 44.1 Customer relationships, identification and ______ ______ __________________ other pertinent data? 44.2 Transactions? ______ ______ __________________ 45 Is there documentation sufficient to permit ______ ______ __________________ reconstruction of individual transaction which will enable the AMLC to compile an audit trail should there be a report made pursuant thereto? 46 Does the documentation include information on the ______ ______ __________________ customer/beneficiary's name, address, nature and date of transaction, type and amount of currency involved, the type and identifying number of account, and information on whether a particular person is a customer or beneficial owner of the transactions? 47 Are the documents referred to under Nos. 44 ______ ______ __________________ and 45 including recordings made under No. 34.1 and any analysis made to detect unusual or suspicious transactions available to the Commission and to the AMLC for its inspection? 48 In case the company's recordkeeping is fully ______ ______ __________________ computerized, do you have an automatic back-up system which is maintained within the prescribed period? 49 Do you apply the five (5) year retention period for ______ ______ __________________ purposes of recordkeeping? 50 Do you maintain a complete file on all transactions ______ ______ __________________ that have been brought to the attention of your Compliance Officer, including transactions that are not reported to the AMLC? 51 Do you require the production of the original ______ ______ __________________ documents referred to herein and do you retain certified copies of said documents, with the name of your employee certifying the documents clearly recorded? 52 If the original copies of the documents cannot be ______ ______ __________________ produced or certified copies cannot be retained, do you record the reasons therefor? 53 Is there a designated officer or staff authorized ______ ______ __________________ to keep or maintain the records referred to herein? Specify below the rank, office or designation: ___________________________________ C. Reporting to the AMLC C.1 General Provisions 54 Do you have a system of mandatory reporting of ______ ______ __________________ both covered transactions and suspicious transactions? 55 Have you appointed a senior officer at ______ ______ __________________ management level with relevant qualifications and experience as Compliance Officer? 56 Do you report to the AMLC all covered and ______ ______ __________________ suspicious transactions within ten (10) working days from occurrence thereof? 57 Do you inform your customers when information ______ ______ __________________ relating to them or whenever their transaction is being reported to the AMLC? 58 Do you have a system of ensuring confidentiality ______ ______ __________________ of the reports made to the AMLC? 59 Whenever any of your officer or employee knows ______ ______ __________________ that the client has engaged in any of the predicate crimes under the AMLA, do you promptly make a report to the AMLC? C.2 Covered Transaction Reports 60 Do you report to the AMLC transactions in cash ______ ______ __________________ or other equivalent monetary instrument involving a total amount in excess of the threshold of Five Hundred Thousand Pesos (PHP500,000.00) within one (1) banking day? C.2 General Provisions 61 Do you report to the AMLC transactions, ______ ______ __________________ regardless of the amounts involved, where any of the following circumstances exists: 61.1 There is no underlying legal or trade ______ ______ __________________ obligation, purpose or economic jurisdiction? 61.2 The client is not property identified; ______ ______ __________________ 61.3 The amount involved is not commensurate ______ ______ __________________ with the business or financial capacity or your client? 61.4 Taking into account all known circumstances, ______ ______ __________________ it may be perceived that the client's transaction is structured in order to avoid being the subject of reporting requirements under the AMLA, as amended? 61.5 Any circumstances relating to the transaction ______ ______ __________________ which is observed to deviate from the profile of the clients and/or past transactions with you? 61.6 The transaction is in any way related to an ______ ______ __________________ unlawful activity or offense under the AMLA, as emended, that is about to be, is being or has been committed. 61.7 Do you inform your customers when ______ ______ __________________ information relating to them or whenever their transaction is being reported to the AMLC? IV. INTERNAL CONTROL AND PROCEDURES, COMPLIANCE AND TRAINING A. Internal Control and Procedure 62 Do you have internal control and procedures aimed ______ ______ __________________ at preventing and impending money laundering? 63 Are your internal policies and procedures on ______ ______ __________________ dealing with money laundering clearly set out and reflected in your Operating Manual? 64 Does your internal written internal reporting ______ ______ __________________ procedure include the following? 64.1 Information to all key staff as to whom ______ ______ __________________ they should report any knowledge or suspicion or money laundering activity? 64.2 Clear reporting chain under which ______ ______ __________________ suspicions of money laundering activity will be passed to the Compliance Officer? 64.3 Access of the Compliance Officer to any ______ ______ __________________ other information which may be necessary in determining whether or not a suspicious transaction report is to be filed? 64.4 A provision that, upon determination of ______ ______ __________________ the suspicious nature of the report, the information contained therein is promptly disclosed to AMLC? 64.5 Maintenance of a register of all reports, ______ ______ __________________ including reports of suspicious transactions to the Compliance Officer but not reported to the AMLC, covered transactions which are not reported to the AMLC, details of the date on which the report is made, the person who made to the report to the Compliance Officer and information sufficient to identify the relevant papers related to the reports? 65 Have you instituted an audit function or procedure ______ ______ __________________ to test the system to ensure adequate compliance with the program? 66 Do you have an adequate screening procedure ______ ______ __________________ to ensure high standards in hiring employees? B. Compliance 67 Have you appointed one or more senior officers ______ ______ __________________ or an appropriate unit to advise the management and staff on the issuance and enforcement of in-house instructions relative to the implementation of the AMLA, as amended, your Operating Manual, personnel training, reporting of covered and suspicious transactions? 68 Does your Compliance Officer have the following ______ ______ __________________ duties? 68.1 Maintenance of a manual of compliance ______ ______ __________________ procedures? 68.2 Ensure compliance by the staff with the ______ ______ __________________ AMLC, its Implementing Rules and Regulations and your Operating Manual? 68.3 Act as liaison officer between you as a ______ ______ __________________ covered institution and the AMLC relative to your compliance with the AMLA? 68.4 Dissemination to the Board, officers and all ______ ______ __________________ employees, memoranda circulars, resolutions, instructions and policies issued by the AMLC or by the Commission in relation to money laundering prevention? 68.5 Prepare and submit to the AMLC written ______ ______ __________________ reports of the covered institution's compliance with the AMLA and its Implementing Rules and Regulations? 69 If you are a branch, subsidiary or affiliate of a ______ ______ __________________ foreign company which is a covered institution in its home country, do you observe anti-money laundering measures consistent with home jurisdiction requirements to the extent allowed by the local laws? C. Training 70 Do you provide education and training for all ______ ______ __________________ your staff and personnel, including directors and officers? If you have conducted such training specify below topics presented, dates of the training and the names of the resource persons: 70.1 __________________________________ ______ ______ __________________ 70.2 __________________________________ ______ ______ __________________ 70.3 __________________________________ ______ ______ __________________ 7 0.4 __________________________________ ______ ______ __________________ 71 Do you provide trainings to all new employees, ______ ______ __________________ regardless of level of seniority? 72 Do you provide continuous trainings to your ______ ______ __________________ cashiers/dealers' representatives or investment representatives/advisory staff or "front-line" staff on matters such as, but not limited to, identification of suspicious transactions, the procedure to be adopted when a transaction is deemed suspicious, and your policy for dealing non-regular customers particularly where large case transactions or complex and unusual transactions are involved? 73 Do you provide trainings to your supervisors and ______ ______ __________________ managers on matters such as, but not limited to, offenses and penalties under the AMLA, the procedures relating to service of production and restraint orders, internal reporting procedures, and the requirement for verification of identity and retention of records? 74 Do you provide, at least once a year, refresher ______ ______ __________________ trainings, or do you conduct on-going training for your key staff on matters such as, but not limited to, updates or developments on money laundering techniques, methods and trends of money laundering and prevention, aspects of the AMLA and obligations thereunder, the requirements on customer identification and due diligence, covered transactions and suspicious transactions reporting? Assistance of the Insurance Commission 75 Do you need assistance of the Commission in ______ ______ __________________ effectively implementing or complying with the AMLA, its Implementing Rules and Regulations, and Circulars issued by the AMLC and the Insurance Commission relative to the AMLA? 76 If you need the assistance of the Commission, ______ ______ __________________ please specify below the kind or type of assistance you need: ________________________________ ________________________________________ ________________________________________ ________________________________________