Aml Questionnaire v3

Anti-Money Laundering (AML) and Combating the Financing of
Terrorism (CFT) Questionnaire

Your cooperation on this matter will assist us to simplify and digitize this process for future screenings of your accounts.
Important Notice: This questionnaire must be signed by the designated Compliance Officer responsible for the overall Anti-Money
Laundering /Countering the Financing of Terrorism (AML/CFT) Program or a senior member of the Management Board.
What is AML/CFT and why is it important to Binance?

Anti-Money Laundering (AML) refers to the legal controls put in place to prevent, detect and report money laundering activities,
where illegally obtained funds are disguised as legitimate income. Countering the Financing of Terrorism (CFT) refers to the legal
controls put in place to prevent, detect and report the solicitation, collection or provision of funds with the intention that they may be
used to support terrorist acts or organizations. For convenience, this document refers below to AML/CFT collectively as
“anti-money laundering.” As a financial institution, Binance has an obligation and a legal responsibility to prevent and detect money
laundering. To achieve this, Binance has implemented a risk-based AML program to comply with laws and regulations where the
firm is active. The firm has also established Sanctions Program in accordance with the Office of Foreign Assets Control (OFAC)
and does not provide services to individuals and companies subject to certain sanctions regimes from around the world. It is our
policy to deal only with customers that share our commitment.
What do we need from you?

Binance needs to know what strategies and policies your company has in place to prevent, detect and report suspected money
laundering (including the use of the platform for fraudulent or other criminal purposes) and terrorist financing activities. This enables
us to understand how your firm assists to combat money laundering and terrorist financing, identify illegal activities, ongoing
controls and preventive measures.
AMLQ11112021
Please be as detailed as possible especially if you conduct manual reviews and risk management on your customers.
I. General Information
Full Legal Name
Legal Form (e.g. Private / Public )
Country of incorporation
Full Legal (Registered) Street

Address
Address of Principal Place of
Business (e.g. operating address)
Business Webpage (URL)
Main Business Activities and

countries in which customers are
located
Industry
AMLQ11112021
II. General Anti-Money Laundering Practices and Procedures
Yes No N/A Comments
a. Is your company subject to the supervision of any
prudential regulatory authority, in any jurisdiction?
If yes, please provide the name of the supervisory /

regulatory authority or authorities and indicate whether
they supervise your compliance with AML/CFT
requirements.
b. Identify the AML/CFT laws to which you are subject and

with which you comply.
c. Does your company have a designated Compliance Officer
responsible for the overall AML/CFT program and for
coordinating and overseeing the AML/CFT program on a
day-to-day basis?
If yes, please provide:

● Full Name
● Position
● Contact Number
● Email
d. Does your company have any written AML/CFT
compliance program?
AMLQ11112021
Yes No N/A Comments
e. How often do you update the AML/CFT program?
f. Does your company have branches / outlets outside of

your home country?
If yes, please indicate the exact countries? If not, please

move on the question 2.g.
g. Are you required to report to the supervisory / regulatory
authorities of your home country if you operate in high risk
countries?
For the definition of high risk countries, Binance relies on

the list shared by FATF and European Commission.
h. How do you ensure that current AML/CFT regulations are
respected within your policies and procedures? For
instance, do you conduct compliance testing?
i. In addition to inspection by government supervisors /

regulations, is your company’s program independently
reviewed by an independent third party (e.g. external
auditors,) that assess AML/CFT practices and procedures
on a periodic or annual basis?
If yes, please list the names of the party that conducted the
independent review and the date of the most recent report.
If no, please move to question 2.j.
AMLQ11112021
Yes No N/A Comments
j. Were there any significant adverse findings identified in the
independent testing of government examinations within
these reports? Have the issues been remediated?
If significant adverse findings were identified, please

provide a detailed statement.
k. Does your company have procedures in place to prevent

you from entering into a relationship with shell bank /
organisation?
III. Transaction Monitoring

Yes No N/A Comments
a. Does your company have a transaction monitoring system
to detect any unusual and/or suspicious transactions?
If yes, please provide the name of the system and indicate

in-house if this is an inhouse system.
If no, please provide information on how transactions are

monitored in your Company including if your Company
performs manual transaction monitoring and if your
employees are trained and required to escalate unusual or
suspicious activity?
AMLQ11112021
Yes No N/A Comments
b. Does your company have processes in place to prevent
and detect any unusual and/or suspicious transactions?
c. Do you risk rate your customers and conduct due diligence

on them based on risk?
d. Does your company have self-assessment procedures

(compliance testing) as part of your internal control
environment to assure compliance with applicable AML/CFT
laws and internal policies and procedures?
e. Does your company have procedures in place in relation to

reporting suspicious transactions to relevant authorities?
If Yes, please explain the procedures.

If No, please provide an explanation as to why this is the
case.
f. Are these processes documented?
g. What is the name of the authorities to which you report

suspicious activity?
h. How long are relevant records retained of investigations of

suspicious activity and decisions to file or not to file reports of
suspicious activity ?
AMLQ11112021
IV. Know Your Customers & Enhanced Due Diligence
Yes No N/A Comments
a. Does your company have procedures in place in relation to
Know Your Customer, Customer Due Diligence, and
Enhanced Due Diligence (EDD)?
b. Do you document and verify your customers’ identity?

What information is verified?
If yes, please provide an example.
Do you obtain and verify the location of your customers?
If yes, please describe the information obtained and the

verification methods used.
What methods do you use to prevent use of the Binance

platform by customers located in jurisdictions that are
prohibited by the Binance terms of use?
AMLQ11112021
Yes No N/A Comments
c. Does your company use documentary or non-documentary
processes for identity verification?
If yes, please describe the methods used.
If the identity cannot be verified do you decline the

relationship?
d. Does your company conduct ongoing due diligence

throughout the relationship with your customer to ensure that
files are up-to-date? Do you periodically update information
on a risk basis? What is the schedule? Do you conduct
updated reviews upon the happening of certain risk events?
e. Does your company conduct Enhanced Due Diligence

(EDD) on higher risk customers? What does that entail?
f. Which of your customers do you consider High Risk and

how is that determined? Are certain categories considered
High Risk and /or is there risk scoring?
AMLQ11112021
Yes No N/A Comments
g. Does your company have procedures in place to determine
the expected transactions profile of customers?
h. Does your company have procedures regarding the

identification, verification and monitoring of Politically
Exposed Persons (PEPs), their family and close associates
and entities owned or controlled by them?
V. Watchlist screenings
Yes No N/A Comments
a. Does your company have automated systems to screen all
transactions against sanctions lists of persons, entities or
countries issued by government/company authorities?
If yes, which tool/database is used for this purpose?

If no, please explain why
b. Please specify which of the following are part of your

program?
● OFAC
● United Nations
● European Union
● Other Local regulation
AMLQ11112021
Yes No N/A Comments
c. Does your company screen new customers against
sanctions lists issued by the government / competent
authorities before transactions are authorised / processed?
d. Does your company also screen new customers against

other lists (e.g. regulatory and law enforcement list)
e. Are customers re-screened against sanctions lists when

there is a change in their corporate ownership structure?
f. How often do you monitor that existing customers do not

appear on a restricted list?
VI. Training
Yes No N/A Comments
a. Does your company provide AML/CFT training to relevant
employees that include:
● Identification and reporting of transactions that must be
reported to government authorities
● Examples of different forms of money laundering /
terrorist financing involving your products / services.
● Information on internal policies to prevent money
laundering / terrorist financing and escalate suspicious
activity and red flags.
AMLQ11112021
Yes No N/A Comments
b. Does your company retain records of its training session,
including attendance records and relevant materials used.
c. Does your company communicate new AML/CFT related

laws or changes to existing AML/CFT related policies or
practices to relevant employees?
Comments
If you wish to state any relevant facts or clarify any matters
regarding your answers to this questionnaire, please do so
here.
Sign off
______________________
Full name:
Designation:
Date:
Contact Number:
Email:
AMLQ11112021

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Anti-Money Laundering (AML) and Combating the Financing of

Terrorism (CFT) Questionnaire

What is AML/CFT and why is it important to Binance?

What do we need from you?

Full Legal Name

Legal Form (e.g. Private / Public )

Full Legal (Registered) Street

Main Business Activities and

If yes, please provide the name of the supervisory /

b. Identify the AML/CFT laws to which you are subject and

If yes, please provide:

e. How often do you update the AML/CFT program?

f. Does your company have branches / outlets outside of

If yes, please indicate the exact countries? If not, please

For the definition of high risk countries, Binance relies on

i. In addition to inspection by government supervisors /

If significant adverse findings were identified, please

k. Does your company have procedures in place to prevent

III. Transaction Monitoring

If yes, please provide the name of the system and indicate

If no, please provide information on how transactions are

c. Do you risk rate your customers and conduct due diligence

d. Does your company have self-assessment procedures

e. Does your company have procedures in place in relation to

If Yes, please explain the procedures.

f. Are these processes documented?

g. What is the name of the authorities to which you report

h. How long are relevant records retained of investigations of

b. Do you document and verify your customers’ identity?

If yes, please provide an example.

Do you obtain and verify the location of your customers?

If yes, please describe the information obtained and the

What methods do you use to prevent use of the Binance

If yes, please describe the methods used.

If the identity cannot be verified do you decline the

d. Does your company conduct ongoing due diligence

e. Does your company conduct Enhanced Due Diligence

f. Which of your customers do you consider High Risk and

h. Does your company have procedures regarding the

If yes, which tool/database is used for this purpose?

b. Please specify which of the following are part of your

d. Does your company also screen new customers against

e. Are customers re-screened against sanctions lists when

f. How often do you monitor that existing customers do not

c. Does your company communicate new AML/CFT related

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