2.1.14 Can securities that you hold in an omnibus account, or an omnibus account itself, be restricted for any reason other than a valid court order? ( ) Yes ( ) No Comments: 2.1.15 Please specify what protection and compensation is available to our organisation if you are unable to meet your obligations. 2.2 Your accounts 2.2.1 Are you able to identify assets / securities held in your omnibus accounts as client assets? ( ) Yes ( ) No Comments: 2.2.2 Acting as custodian, do you provide segregation: a) between your proprietary holdings and clients’ holdings? ( ) Yes ( ) No b) between clients’ proprietary holdings and your client’s clients’ holdings? ( ) Yes ( ) No c) throughout the custody chain including at CSD level? ( ) Yes ( ) No Comments: 2.2.3 Are assets settled directly into a segregated client account or are they settled into a
Securities Cash (Frequency of reconciliation) Automation (Frequency of reconciliation) Automation CSD (Balance) ( ) Intraday ( ) ( ) Weekly ( ) Monthly ( ) > Monthly ( ) Not Applicable ( ) Fully automated ( ) Semi automated ( ) Manual ( ) Not Applicable ( ) Intraday ( ) Daily ( ) Weekly ( ) Monthly ( ) > Monthly ( ) Not Applicable ( ) Fully automated ( ) Semi automated ( ) Manual ( ) Not Applicable CSD (Transaction) ( ) Intraday ( ) Daily ( ) Weekly ( ) Monthly ( ) > Monthly ( ) Not Applicable ( ) Fully automated ( ) Semi automated ( ) Manual ( ) Not Applicable ( ) Intraday ( ) Daily ( ) Weekly ( ) Monthly ( ) > Monthly ( ) Not Applicable ( ) Fully automated ( ) Semi automated ( ) Manual ( ) Not Applicable Central Bank (Balance) ( ) Intraday ( ) Daily ( ) Weekly ( ) Monthly ( ) > Monthly ( ) Not Applicable ( ) Fully automated ( ) Semi automated ( ) Manual ( ) Not Applicable ( ) Intraday ( ) Daily ( ) Weekly ( ) Monthly ( ) > Monthly ( ) Not Applicable ( ) Fully automated ( ) Semi automated ( ) Manual ( ) Not Applicable Central Bank (Transactions) ( ) Intraday ( ) Daily ( ) Weekly ( ) Monthly ( ) > Monthly ( ) Not Applicable ( ) Fully automated ( ) Semi automated ( ) Manual ( ) Not Applicable ( ) Intraday ( ) Daily ( ) Weekly ( ) Monthly ( ) > Monthly ( ) Not Applicable ( ) automated ( ) Semi automated ( ) Manual ( ) Not Applicable Registrar (Balance) ( ) Intraday ( ) Daily ( ) Weekly ( ) Monthly ( ) > Monthly ( ) Not Applicable ( ) automated ( ) Semi automated ( ) Manual ( ) Not Applicable ( ) Intraday ( ) Daily ( ) Weekly ( ) Monthly ( ) > Monthly ( ) Not Applicable ( ) automated ( ) Semi automated ( ) Manual ( ) Not Applicable Registrar (Transactions) ( ) Intraday ( ) Daily ( ) Weekly ( ) Monthly ( ) > Monthly ( ) Not Applicable ( ) automated ( ) Semi automated ( ) Manual ( ) Not Applicable ( ) Not Applicable Delegated ( ) Intraday ( ) ( ) Weekly ( ) Fully automated ( ) Semi ( ) Not Applicable
3.6.5 Describe your process for monitoring changes to any regulation or legislation that may affect your financial crime policies. 3.6.6 In the last 12 months have there been any material changes to your policies to combat financial crime? If yes, please provide details. ( ) Yes ( ) No Comments: 3.6.7 How does your organisation identify, report (including to whom) and monitor suspicious securities and cash transactions? 3.6.8 Do you have a systematic and technological capability to ensure that any suspicious securities and cash transactions are identified, monitored and reported? If No, please describe how you ensure that suspicious transactions are adequately monitored and managed and how your system and/or process is kept up-to-date? Systematic and technological capability ( ) Yes ( ) No If No, how are suspicious transactions monitored and managed? How is your system and/or process kept up-to-date?
Automated, technological capability Embargoed jurisdictions ( ) Yes ( ) No Individuals or entities that are the target of US, UK, UN or EU sanctions programs ( ) Yes ( ) No Anonymous account holders ( ) Yes ( ) No Shell Banks ( ) Yes ( ) No Comments: 3.6.21 Does your institution perform sanction screening against the OFAC, UN and EU sanctions lists at the time of on-boarding and for each transaction? ( ) Yes ( ) No Comments: 3.6.22 Please provide a copy of your US Patriot Act Compliance certificate. Please attach file here: [File Attachment] Comments: 3.6.23 Which department in your organisation is responsible for the implementation, monitoring, escalation, reporting, and management of any sanctions? 3.6.24 Does your bank operate a formal Code of Conduct for procurement?
operational reporting capabilities planned for the next 12 months. 4.2 Protecting your systems 4.2.1 Do you have a data security policy? If yes, please attach or provide details. ( ) Yes ( ) No Please upload files here: [File Attachment] Comments: 4.2.2 Does your organisation have spyware protection installed on all servers and workstations? ( ) Yes ( ) No Comments: 4.2.3 Please outline your anti-spyware checking procedures and confirm that your anti-spyware software is updated whenever a new version is released. 4.2.4 Does your organisation have protection installed on all servers and workstations? ( ) Yes ( ) No Comments: 4.2.5 Please outline your anti-virus checking procedures and confirm that your anti-virus software is updated whenever a new version is released. Comments: