LUCID EWRA

ASSESSMENT CRITERIA

RISK LEVEL

EXPLAINER

REMARK

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

Medium High

The entity is in Banking industry

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

High

The entity operate in Vietnam, Singapore and Hong Kong, with main source of income comes from Vietnam

II. Risk of money laundering from business activities

1. Risk of money laundering from customers

Medium Low

Ratio of High Risk Customer is from 2 to 4 percent

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

Low

Main product/service is Saving.

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

3.1 Evaluate bank's transaction channels

Medium High

Around 70-80% of customers transact via non-Face to face channels

3.2 Evaluate 3rd-party transacion channels

Medium High

Around 70-80% of customers transact via non-Face to face channels

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

Medium High

Internal regulations and policies satisfied 70-80% items of AML Regulation (quantitative)

2. The level of compliance with AML legislation (qualitative)

Medium High

Internal regulations and policies are 70-80% similar with Regulation (qualitative)

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

Medium High

Internal regulations and policies can cover 70-80% AML Risk

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

Medium

Internal policies are reviewed every 12 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

Medium

There is no system in place, reports are done manually

1.2 STR report information

Medium

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1.3 Accuracy of CTR, DWT, EFT Report

Medium

Around 10-15% of submitted report are feedback with inaccuracy

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

Medium

Total of 3 training sessions was organized in the past 12 months

2.2 Results of training sessions

Medium

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2.3 Ratio of trained staff

Medium

Around 70-80% of staff were trained in the past 12 months

2.4 Group of trained staff

Medium

Training were provided for Compliance Officer and Manager

3. The level of efficiency of AML management.

3.1 Errors in operation (SBV, Internal Audit)

Low

Internal Audit discovered some errors classified as low risk.

3.2 The extent to which problems have been remedied

Low

No more remainning problems.

3.3 Automation level (software application)

Medium Low

Applied software solution in basic level, having KYC, Transaction Monitoring and Payment Screening.