LUCID EWRA

ASSESSMENT CRITERIA

A. Money laundering risk

I. Risk of money laundering from the business environment of the reporting entity

1. Risk of money laundering from the industry or sector in which the reporting entity operates

2. Risk of money laundering from the country or jurisdictions in which the reported entity operates

Country

Revenue (USD)

II. Risk of money laundering from business activities

1. Risk of money laundering from customers

- Number of High Risk Customer:

- Total Number of Customer:

2. Risk of money laundering from products and services provided to customers

Products and Services

Revenue (USD)

3. Risk of money laundering from the way products and services are distributed

3.1 Evaluate bank's transaction channels

Transaction Channel

Revenue (USD)

3.2 Evaluate 3rd-party transacion channels

Transaction Channel

Revenue (USD)

B. The level of compliance with the internal AML policies and regulations

I. Comprehensiveness of internal policies and regulations on AML

1. The adequacy of internal policies and regulations on AML

- Adequacy completeness ratio:

2. The level of compliance with AML legislation

- Compliance completeness ratio:

3. The level of consistency with the level of money laundering risk of the reporting entity

- Consistency ratio:

4. The periodic re-evaluation of internal policies to comly with changes in law or regulations and operational practices

- Re-evaluation frequency (in months):

II. The effectiveness of the implementation of internal policies and regulations on AML

1. The efficiency of implementation of AML measures

1.1 Availability of compliance system and reporting

- Customer Screening (KYC)

- Transaction Monitoring

- Payment Screening

1.2 STR report information

- Number of Alerts:

- Number of STR Reports:

- Number of False Positive:

1.3 Accuracy of CTR, DWT, EFT Report

- Number of CTR, DWT, EFT Report:

- Number of inaccuracy report/ complain:

2. The level of understanding, compliance with rules and professional standards of leaders and employees with relevant responsibilities for AML

2.1 Number of training sessions

2.2 Results of training sessions

- Ratio of trained staff pass the evaluation

2.3 Ratio of trained staff

2.4 Group of trained staff

- Branch Teller

- Branch Manager

- Compliance Officer

3. The level of efficiency of AML management.

3.1 Errors in operation (SBV, Internal Audit)

- Ammount of Errors

3.2 Software Application

- Automation level