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{"sheet":"8.2 General","index":0,"n_rows":71,"n_cols":6,"rows_kept":71,"cut":false,"hidden":false,"merged":[]}
[]
["8.2.1","Legal Structure"]
[]
[null,"What is the legal structure of your institution?",null,"AAA"]
[null,"If your institution is a subsidiary within a group:\nPlease state the name of the parent entity of the group, the country where the parent entity of the group is established, and the AML/CFT supervisory authority of the parent entity of the group"]
[null,"Name of the ultimate EEA parent entity",null,"AAB"]
[null,"LEI of the ultimate EEA parent entity",null,"AAL"]
[null,"Country where the ultimate EEA parent entity is established",null,"AAC"]
[null,"The AML/CFT supervisory authority of the ultimate EEA parent entity",null,"AAD"]
[null,"Name of the global parent entity of the group",null,"BHT"]
[null,"LEI of the global parent entity of the group",null,"BHU"]
[null,"Country where the global parent entity of the group is established",null,"BHV"]
[null,"The AML/CFT supervisory authority of the global parent entity of the group",null,"BHW"]
[null,"If your institution is a branch of an entity:\nPlease state the name of the parent entity, the country where the parent entity is established, and the AML/CFT supervisory authority of the parent entity"]
[null,"Name of the ultimate EEA parent entity",null,"AAE"]
[null,"LEI of the ultimate EEA parent entity",null,"AAM"]
[null,"Country where the ultimate EEA parent entity is established",null,"AAF"]
[null,"The AML/CFT supervisory authority of the ultimate EEA parent entity",null,"AAG"]
[null,"Name of the global parent entity",null,"BHX"]
[null,"LEI of the global parent entity",null,"BHY"]
[null,"Country where the global parent entity is established",null,"BHZ"]
[null,"The AML/CFT supervisory authority of the global parent entity",null,"BIA"]
[]
["8.2.2","International Presence"]
[]
[null,"Does your institution operate within the EU/EEA based on Freedom of Establishment (FOE) and/or Freedom of Service (FOS)?",null,"AAH"]
[]
[null,"Is your institution active outside the EU/EEA through subsidiaries, agents, branch offices, distributors, or other physical presence?",null,"ACO"]
[]
[null,"Select each EEA country and for each EEA country enter the Value of Transactions by customers that are resident in that EEA country where the institution operates on a FOE basis and on a FOS basis."]
[null,"Select EEA Country",null,"FOE","FOS"]
[null,"AAI",null,"AAJ","AAK"]
[null,"AT",null,"< enter number >","< enter number >"]
[null,"BE",null,"< enter number >","< enter number >"]
[null,"BG",null,"< enter number >","< enter number >"]
[null,"CY",null,"< enter number >","< enter number >"]
[null,"CZ",null,"< enter number >","< enter number >"]
[null,"DE",null,"< enter number >","< enter number >"]
[null,"DK",null,"< enter number >","< enter number >"]
[null,"EE",null,"< enter number >","< enter number >"]
[null,"ES",null,"< enter number >","< enter number >"]
[null,"FI",null,"< enter number >","< enter number >"]
[null,"FR",null,"< enter number >","< enter number >"]
[null,"GR",null,"< enter number >","< enter number >"]
[null,"HR",null,"< enter number >","< enter number >"]
[null,"HU",null,"< enter number >","< enter number >"]
[null,"IS",null,"< enter number >","< enter number >"]
[null,"IT",null,"< enter number >","< enter number >"]
[null,"LI",null,"< enter number >","< enter number >"]
[null,"LT",null,"< enter number >","< enter number >"]
[null,"LU",null,"< enter number >","< enter number >"]
[null,"LV",null,"< enter number >","< enter number >"]
[null,"MT",null,"< enter number >","< enter number >"]
[null,"NL",null,"< enter number >","< enter number >"]
[null,"NO",null,"< enter number >","< enter number >"]
[null,"PL",null,"< enter number >","< enter number >"]
[null,"PT",null,"< enter number >","< enter number >"]
[null,"RO",null,"< enter number >","< enter number >"]
[null,"SE",null,"< enter number >","< enter number >"]
[null,"SI",null,"< enter number >","< enter number >"]
[null,"SK",null,"< enter number >","< enter number >"]
[]
["8.2.3","Statement of Compliance"]
[]
[null,"The Central Bank requires the information sought in this REQ pursuant to section 22 of the Central Bank (Supervision and Enforcement) Act 2013. Take notice that to knowingly provide false or misleading information in purported compliance with this requirement is an offence under section 32(1)(c) of the Central Bank (Supervision and Enforcement) Act 2013 and may be relied upon in subsequent administrative sanctions or court proceedings.\n\nI confirm that to the best of my/our knowledge that the Institution has materially complied with all of its obligations and requirements under relevant anti-money laundering, countering the financing of terrorism and financial sanctions legislation including Part 4 of the CJA 2010, as amended, Criminal Justice (Terrorist Offences) Act 2005 and financial sanctions regulations during the 12 month period covered by this REQ where the REQ is being completed for the first time or where an REQ has previously been completed in the period since the last filing of an REQ.",null,"ACP"]
[]
[]
[null,"If the answer is No to the Statement of Compliance above, please provide a brief summary of material non-compliance.",null,"ACQ"]
[]
[null,null,null,"Name","Position Held","PCF"]
[null,"Name and position of the person signing this Statement of Compliance on behalf of the Institution",null,"ACR","ACS","ACT"]

{"sheet":"8.3 Inherent Risk","index":1,"n_rows":281,"n_cols":8,"rows_kept":281,"cut":false,"hidden":false,"merged":[]}
[null,null,"Customers"]
[null,null,"The questions below relate to the customers with which your institution entered into a customer/business relationship."]
[]
[null,"8.3.1","Customer segments"]
[]
[null,null,"Please specify the total number of all customers at the end of the preceding calendar year segmented by natural persons, legal entities.\n\nPlease enter a number (or 0) in all fields in this table.\n",null,"No. of All Customers","No. of Active Customers","No. of Transactions by Active Customers","Value of Transactions by Active Customers"]
[null,null,"Natural Persons (i.e., Personal customers, Retail customers)",null,"ACU","BIM","BIP","BIS"]
[null,null,"Legal entities (i.e., Non-personal customers, Non-retail customers, Legal persons and/or other entities and/or legal structures and/or arrangements)",null,"ACV","BIN","BIQ","BIT"]
[null,null,"Occasional transactions/Walk-ins",null,"BIO",null,"BIR","BIU"]
[]
[null,null,"Please specify the total number of customers at the end of the preceding calendar year, segmented by natural persons and legal entities, and their attributes.\n\nPlease enter a number (or 0) in all fields in this table.\n\n"]
[null,null,"Segment",null,"No. of Customers"]
[null,null,"ACW",null,"ACX"]
[null,null,"NP_physcially_on",null,"< enter number >"]
[null,null,"NP_remotely_on",null,"< enter number >"]
[null,null,"NP_not_categorised",null,"< enter number >"]
[null,null,"NP_blocked",null,"< enter number >"]
[null,null,"NP_suspended",null,"< enter number >"]
[null,null,"NP_5000000",null,"< enter number >"]
[null,null,"NP_50000000",null,"< enter number >"]
[null,null,"LE_physcially_on",null,"< enter number >"]
[null,null,"LE_remotely_on",null,"< enter number >"]
[null,null,"LE_not_categorised",null,"< enter number >"]
[null,null,"LE_blocked",null,"< enter number >"]
[null,null,"LE_suspended",null,"< enter number >"]
[null,null,"LE_SME",null,"< enter number >"]
[null,null,"LE_corporate",null,"< enter number >"]
[null,null,"LE_TCSP",null,"< enter number >"]
[null,null,"Private_banking",null,"< enter number >"]
[null,null,"Complex",null,"< enter number >"]
[null,null,"Cash_intensive",null,"< enter number >"]
[null,null,"Shell_institution",null,"< enter number >"]
[null,null,"CASP",null,"< enter number >"]
[null,null,"Credit_institution",null,"< enter number >"]
[null,null,"Financial_institution",null,"< enter number >"]
[null,null,"Government_body",null,"< enter number >"]
[null,null,"SPV",null,"< enter number >"]
[null,null,"NPO",null,"< enter number >"]
[null,null,"NPO_non_EEA",null,"< enter number >"]
[null,null,"Cust_non_EEA",null,"< enter number >"]
[]
[null,"8.3.2","Sector"]
[null,null,"Total number of customers with high risk activities",null,"BML"]
[]
[null,null,"Please specify the total number of high risk customers at the end of the preceding calendar year, to which your institution provides services, that are active in the sectors listed below as the end of the preceding calendar year.\n\nThis concerns the sector regarding your customer's regular or principal activity.\n\nPlease enter a number (or 0) in all fields in this table."]
[null,null,"Sector",null,"No. of High Risk Customers"]
[null,null,"ADA",null,"ADB"]
[null,null,"Mining",null,"< enter number >"]
[null,null,"Oil_gas",null,"< enter number >"]
[null,null,"Energy",null,"< enter number >"]
[null,null,"Defence",null,"< enter number >"]
[null,null,"Precious_metal",null,"< enter number >"]
[null,null,"Art_dealer",null,"< enter number >"]
[null,null,"Crypto",null,"< enter number >"]
[null,null,"Gambling",null,"< enter number >"]
[null,null,"Contruction",null,"< enter number >"]
[null,null,"Real_estate",null,"< enter number >"]
[null,null,"TCSP",null,"< enter number >"]
[null,null,"Religion",null,"< enter number >"]
[null,null,"Freight",null,"< enter number >"]
[null,null,"Advisory",null,"< enter number >"]
[null,null,"IP",null,"< enter number >"]
[null,null,"MTOPSP",null,"< enter number >"]
[null,null,"Pharm",null,"< enter number >"]
[null,null,"Scrap_dealer",null,"< enter number >"]
[null,null,"Sale_motor",null,"< enter number >"]
[null,null,"Sale_boat",null,"< enter number >"]
[null,null,"Catering",null,"< enter number >"]
[null,null,"Crowdfunding",null,"< enter number >"]
[null,null,"Sport",null,"< enter number >"]
[null,null,"Stockbroker",null,"< enter number >"]
[null,null,"Financial_service",null,"< enter number >"]
[null,null,"Other_high_risk",null,"< enter number >"]
[null,null,"Other_sector",null,"< enter number >"]
[]
[null,null,"Products and Services"]
[]
[null,"8.3.3","Anonymity"]
[]
[null,null,"Is it possible for your institution's customers to conceal any aspect of their identity or remain anonymous when using the products, services, and transactions offered by your institution?",null,"ADZ"]
[null,null,"If yes, provide details on the nature of the concealment of identity or anonymity available for customers using the products, services, and transactions offered by your institution.",null,"AAN"]
[null,null,null,null,"No. of Products and/or Services","No. of Transactions","Value of Transactions "]
[null,null,"State the number of products, services and the total number and value (EUR) of transactions in the preceding calendar year.",null,"AEA","AEB","AEC"]
[]
[null,"8.3.4","Correspondent Relationship"]
[]
[null,null,"Does the corresponding relationship service provided by your institution offer the option that the account can be used by other respondent institutions that have a direct relationship with the respondent but not with the your institution ('nesting', or downstream clearing), which means that your institution is indirectly providing services to other institutions that are not the respondent.",null,"AEL"]
[null,null,"State the proportion of the total corresponding relationship accounts that have been used in the manner above during the preceding calendar year.",null,"AEM"]
[null,null,"Does the corresponding relationship service provided by your institution offer the option that the account can be used by other entities within the respondent's group that have not themselves been subject to your institution's due diligence.",null,"AEN"]
[null,null,"State the proportion of the total corresponding relationship accounts that have been used in the manner above during the preceding calendar year.",null,"AEO"]
[null,null,"Does the corresponding relationship service provided by your institution include the opening of a payable-through account, which allows the respondent's customers to carry out transactions directly on the account of the respondent?",null,"AEP"]
[null,null,"Total Value (EUR) of transactions going through payable-through accounts in the preceding calendar year (incoming)",null,"BED"]
[null,null,"Total Value (EUR) of transactions going through payable-through accounts in the preceding calendar year (outgoing)",null,"BEE"]
[null,null,"Total Value (EUR) of transactions going through nested accounts in the preceding calendar year (incoming)",null,"BGV"]
[null,null,"Total Value (EUR) of transactions going through nested accounts in the preceding calendar year (outgoing)",null,"BGW"]
[]
[null,"8.3.5","Cryptos and tokens"]
[]
[null,null,"Does your institution acquire or trade in any of the following products?"]
[null,null,"Financial products with cryptos as the underlying value",null,"AEQ"]
[null,null,"Cryptos (e.g. Bitcoin, Ethereum, Ripple, Bitcoin Cash, Cardano, Litecoin etc.)",null,"AER"]
[null,null,"Crypto tokens (issued through an Initial Coin Offering)",null,"AES"]
[]
[null,null,"What financial products with cryptos as the underlying value did you acquire or trade in?",null,"AET"]
[]
[null,null,"What are the total numbers and values (EUR) of these transactions in the preceding calendar year?",null,"No. of Transactions","Value of Transactions"]
[null,null,"Exchange Traded Funds (ETFs)",null,"AEU","AEV"]
[null,null,"Other financial products traded on the regulated market",null,"AEW","AEX"]
[null,null,"Other financial products traded on the non-regulated market",null,"AEY","AEZ"]
[null,null,"Bitcoin",null,"AFA","AFB"]
[null,null,"Ethereum",null,"AFC","AFD"]
[null,null,"Crypto tokens",null,"AFE","AFF"]
[null,null,"Other cryptos",null,"AFG","AFH"]
[]
[null,null,"If you entered a value greater than 0 at \"Other financial products traded on the regulated market\" or \"Other financial products traded on the non-regulated market\", please specify which financial products.",null,"AFI"]
[null,null,"If you entered a value greater than 0 at “Other cryptos\", please specify which cryptos.",null,"AFJ"]
[]
[null,null,"Does your institution offer crypto wallets?",null,"AFK"]
[null,null,"If your institution currently does not offer crypto wallets, does it intend to do so in the future?",null,"AFL"]
[]
[null,null,"Please specify if your institution's engages with any of the following with respect to virtual assets"]
[null,null,"Cryptocurrency trading services",null,"AFM"]
[null,null,"Custody services",null,"AFN"]
[null,null,"Investment products",null,"AFO"]
[null,null,"Blockchain Technology and partnership",null,"AFP"]
[]
[null,"8.3.6","Deposits and Withdrawals"]
[]
[null,null,null,null,"Deposits\n(by natural person customers)","Deposits\n(by legal entity customers)","Withdrawals\n(by natural person customers)","Withdrawals\n(by legal entity customers)"]
[null,null,"Cash - Total Number (No.) of Transactions",null,"AFQ","AFV","AGA","AGF"]
[null,null,"Cash - Total Value (EUR) of Transactions",null,"AFR","AFW","AGB","AGG"]
[null,null,"Cash - Total Number (No.) of Transactions amounting to EUR 10,000 or more",null,"AFS","AFX","AGC","AGH"]
[null,null,"Cash - Total Value (EUR) of Transactions amounting to EUR 10,000 or more",null,"AFT","AFY","AGD","AGI"]
[null,null,"Cash - Highest Value (EUR) per transaction",null,"AFU","AFZ","AGE","AGJ"]
[]
[null,null,"Cash - Number of customers totalling cash transactions over EUR 20,000 or more during the preceding calendar year",null,"AOF"]
[]
[null,"8.3.7","Currency Cash Exchange"]
[]
[null,null,null,null,"Buy","Sell"]
[null,null,"Total Number (No.) of Transactions",null,"AGK","AGL"]
[null,null,"Total Value (EUR) of Transactions",null,"AGM","AGN"]
[null,null,"Total Number (No.) of Transactions amounting to EUR 1,000 or more",null,"AGO","AGP"]
[null,null,"Total Value (EUR) of Transactions amounting to EUR 1,000 or more",null,"AGQ","AGR"]
[null,null,"Highest Value (EUR) of single transaction",null,"AGS","AGT"]
[]
[null,null,"Total Value (EUR) of transactions cash-to-cash carried out during the preceding calendar year",null,"AOG"]
[]
[null,"8.3.8","Safe Deposit Boxes"]
[]
[null,null,"No. of active customers who avail of safe deposit box services",null,"AGU"]
[null,null,"No. of safe deposit boxes rented out to your customers",null,"AGV"]
[null,null,"No. of locations where safe deposit boxes are offered for rent",null,"AGW"]
[]
[null,"8.3.9","Virtual IBAN Accounts"]
[]
[null,null,null,null,"Yes/No","No. of master accounts provided with the service"]
[null,null,"Does your institution provide the facility to its customers to map a range of virtual IBANs against an IBAN-identifiable master account held in their name? If yes, please report the total number of master accounts provided with this service.",null,"AGX","AGY"]
[null,null,"Does your institution offer its customers virtual IBAN accounts which are mapped against an IBAN-identifiable master account in the name of your entity held with another institution? If yes, please report the total number of master accounts provided with this service.",null,"AGZ","AHA"]
[]
[null,null,"Number of transactions on Virtual IBANs (incoming) in the preceding calendar year",null,"BEF"]
[null,null,"Total Value (EUR) of transactions on Virtual IBANs (incoming) in the preceding calendar year",null,"BEG"]
[null,null,"Number of transactions on Virtual IBANs (outgoing) in the preceding calendar year",null,"BEH"]
[null,null,"Total Value (EUR) of transactions on Virtual IBANs (outgoing) in the preceding calendar year",null,"BEI"]
[null,null,"Total Number of re-issued IBANs",null,"BEJ"]
[null,null,"Total Number of re-issued IBANs where the end-user is not a customer of the obliged entity",null,"BEK"]
[]
[null,"8.3.10","Prepaid Cards"]
[]
[null,null,null,null,"In issuance by your institution at the end of the preceding calendar year","First issued by your institution during the preceding calendar year"]
[null,null,"No. of prepaid cards",null,"AHB","AHI"]
[null,null,"No. of reloadable prepaid cards",null,"AHC","AHJ"]
[null,null,"No. of customers to whom prepaid cards were issued to",null,"AHD","AHK"]
[null,null,"No. of customers with more than 3 prepaid cards",null,"AHE","AHL"]
[null,null,"Total value (EUR) of issued prepaid cards",null,"AHF","AHM"]
[null,null,"Total value (EUR) outstanding on issued prepaid cards",null,"AHG","AHN"]
[null,null,"No. of prepaid cards with outstanding balance > EUR 150",null,"AHH","AHO"]
[]
[null,"8.3.11","Lending"]
[null,null,null,null,"Number","Value"]
[null,null,"Total Number and Value (EUR) of outstanding loans",null,"BEL","BGO"]
[null,null,"Total Number and Value (EUR) of loans granted during the preceding calendar year",null,"BEM","BGP"]
[null,null,"Total Number and Value (EUR) of outstanding asset backed loans with cash collateral",null,"BEN","BGQ"]
[null,null,"Total Number and Value (EUR) of loan repayments during the preceding calendar year",null,"BEO","BGR"]
[null,null,"Total Number and Value (EUR) of prematurely repaid loans during the preceding calendar year",null,"BEP","BGS"]
[null,null,"Total Number and Value (EUR) of loan repayments from non-EEA countries during the preceding calendar year",null,"BEQ","BGT"]
[null,null,"Total Number and Value (EUR) of consumer loans granted during the preceding calendar year that are not associated to the acquisition of any product or service",null,"BER","BGU"]
[]
[null,"8.3.12","Factoring"]
[]
[null,null,"Total Number of factoring contracts granted in the preceding calendar year",null,"BES"]
[null,null,"Total Value (EUR) of factoring contracts granted during the preceding calendar year",null,"BET"]
[null,null,"Total Value (EUR) of factoring contracts granted to obligors established in non-EEA countries during the preceding calendar year",null,"BEU"]
[]
[null,"8.3.13","Investment Services and Activities"]
[null,null,"Reception and transmission of orders - Number of retail clients",null,"BIY"]
[null,null,"Reception and transmission of orders - Number of professional clients",null,"BIZ"]
[null,null,"Reception and transmission of orders - proportion of value of orders transmitted involving unlisted financial instruments, other than financial instruments issued by the obliged entity or its group",null,"BJA"]
[null,null,"Reception and transmission of orders - Number of AML/CFT regulated customers outside the EEA",null,"BJB"]
[null,null,"Custody - Number of retail clients",null,"BJC"]
[null,null,"Custody - Number of professional clients",null,"BJD"]
[null,null,"Custody - proportion of assets under custody for which your institution does not have a direct business relationship with the final investor",null,"BJE"]
[null,null,"Custody - Number of AML/CFT regulated customers outside the EEA",null,"BJF"]
[null,null,"Portfolio management - Number of retail clients",null,"BJG"]
[null,null,"Portfolio management - Number of professional clients",null,"BJH"]
[null,null,"Portfolio management - Total assets under management",null,"BJI"]
[null,null,"Portfolio management - Number of customers who your institution provides portfolio management (including custody) services to and your institution holds assets with a value of at least  EUR 5,000,000",null,"BJJ"]
[]
[null,"8.3.14","Money Remittance"]
[null,null,"Total Number of money remittance payments in the preceding calendar year (incoming)",null,"BJK"]
[null,null,"Total Number of money remittance payments in the preceding calendar year (outgoing)",null,"BJL"]
[null,null,"Total Value (EUR) of remittance payments in the preceding calendar year (incoming)",null,"BJM"]
[null,null,"Total Value (EUR) of remittance payments in the preceding calendar year (outgoing)",null,"BJN"]
[null,null,"Total Number of money remittance transactions above EUR 1,000 in the preceding calendar year (incoming)",null,"BJO"]
[null,null,"Total Number of money remittance transactions above EUR 1,000 in the preceding calendar year (outgoing)",null,"BJP"]
[]
[null,"8.3.15","Exchange crypto-fiat"]
[null,null,"Total amount (EUR) crypto-fiat in the preceding calendar year",null,"BJX"]
[null,null,"Total number of transactions crypto-fiat in the preceding calendar year",null,"BJY"]
[null,null,"Number of customers using this type of service in the preceding calendar year",null,"BJZ"]
[null,null,"Total number of transactions crypto-fiat to unhosted wallets in the preceding calendar year",null,"BKA"]
[null,null,"Total number of transactions crypto-fiat from unhosted wallets in the preceding calendar year",null,"BKB"]
[]
[null,"8.3.16","Exchange fiat-crypto"]
[null,null,"Total amount (EUR) fiat-crypto in the preceding calendar year",null,"BKC"]
[null,null,"Total number of transactions fiat-crypto in the preceding calendar year",null,"BKD"]
[null,null,"Number of customers using this type of service in the preceding calendar year",null,"BKE"]
[null,null,"Total number of transactions fiat-crypto to unhosted wallets in the preceding calendar year",null,"BKF"]
[null,null,"Total number of transactions fiat-crypto from unhosted wallets in the preceding calendar year",null,"BKG"]
[]
[null,"8.3.17","Exchange crypto-crypto"]
[null,null,"Total amount (EUR) crypto-crypto in the preceding calendar year",null,"BKH"]
[null,null,"Number of customers using this type of service in the preceding calendar year",null,"BKI"]
[null,null,"Total number of transactions crypto-crypto to unhosted wallets in the preceding calendar year",null,"BKJ"]
[null,null,"Total number of transactions crypto-crypto from unhosted wallets in the preceding calendar year",null,"BKK"]
[]
[null,"8.13.18","Transfer crypto-assets"]
[null,null,"Total amount (EUR) that customers transferred in the preceding calendar year",null,"BKL"]
[null,null,"Number of customers using this type of service in the preceding calendar year",null,"BKM"]
[null,null,"Total number of transactions to unhosted wallets in the preceding calendar year",null,"BKN"]
[null,null,"Total number of transactions from unhosted wallets in the preceding calendar year",null,"BKO"]
[]
[null,"8.3.19","Custody of Crypto Assets"]
[null,null,"Total number of customers owning crypto-assets",null,"BKU"]
[null,null,"Total value (EUR) hosted on the custodian wallets",null,"BKV"]
[]
[null,"8.3.20","Crowdfunding"]
[null,null,"Total Value (EUR) of funding projects in the preceding calendar year",null,"BKP"]
[null,null,"Total Number of projects being funded in the preceding calendar year",null,"BKQ"]
[null,null,"Total Number of donors from high-risk countries",null,"BKR"]
[null,null,"Total Number of projects where the owner is from a high-risk country",null,"BKS"]
[null,null,"Total Number of projects funded for philanthropic purposes in the preceding calendar year",null,"BKT"]
[]
[null,"8.3.21","Other Products and/or Services"]
[]
[null,null,"Please provide No. of Active Customers at the end of the preceding calendar year and their total numbers and values (EUR) of transactions during the preceding calendar year."]
[null,null,null,null,"No. of Active Customers","Value of Transactions","No. of Transactions"]
[null,null,"Aircraft Finance",null,"AHP","AHX","AIF"]
[null,null,"Maritime Finance",null,"AHQ","AHY","AIG"]
[null,null,"Wealth Management",null,"AHR","AHZ","AIH"]
[null,null,"Treasury Services",null,"AHS","AIA","AII"]
[null,null,"Securities Services",null,"AHT","AIB","AIJ"]
[null,null,"Depositary Services",null,"AHU","AIC","AIK"]
[null,null,"Merchant Services",null,"AHW","AIE","AIM"]
[]
[]
[null,null,"Distribution Channels and Third Parties"]
[]
[null,"8.3.22","Intermediaries and Distribution Channels"]
[]
[null,null,"Does your institution use intermediaries for the provision of services?",null,"AIN"]
[null,null,"State the total number of intermediaries that your institution registered as at the end of the preceding calendar year.",null,"AIO"]
[null,null,"The number of the intermediaries above that are not themselves designated persons under the CJA 2010 or national legislation.",null,"AIP"]
[null,null,"The number of new customers onboarded in the preceding calendar year by intermediaries that are not themselves obliged entities under Regulation (EU) 2024/1624 or national legislation.",null,"BEC"]
[null,null,"Indicate the total value of paid commissions and fees (EUR) in the preceding calendar year",null,"AIQ"]
[null,null,"Indicate the proportion of new customers introduced through an intermediary in the preceding calendar year. ",null,"AIR"]
[]
[null,"8.3.23","Remote Onboarding"]
[null,null,null,null,"Natural person customers","Legal entity customers"]
[null,null,"Please state the proportion of total customers accepted via remote onboarding (including remotely onboarded by your institution's intermediaries) in the preceding calendar year.",null,"AIT","AIW"]
[null,null,"Please state the proportion of total customers accepted via remote onboarding (including remotely onboarded by your institution's intermediaries) in the preceding calendar year that were rated high risk per your institution's customer risk assessment profiling.\n",null,"AIU","AIX"]

{"sheet":"8.4 Mitigation & Control","index":2,"n_rows":413,"n_cols":6,"rows_kept":413,"cut":false,"hidden":false,"merged":[[228,2,228,3]]}
[null,"Mitigation & Control"]
[]
["8.4.1","Business Wide Risk Assessment"]
[]
[null,"Does your institution conduct a Business Wide Risk Assessment ('BWRA')?","AIY"]
[]
[null,"Did Senior Management approve the latest version of the BWRA?","AIZ"]
[null,"What is the approval date of your institution's most recent BWRA","AJA"]
[null,"What is the frequency of BWRA review by your institution","AJB"]
[null,"Did the most recent BWRA review prompt an update to your institution's policies, procedures, oversight measures, or risk appetite","AJC"]
[null,"Describe (briefly) the changes that have been implemented in relation to the BWRA performed and why the changes have been made","AJD"]
[]
[null,"Are the following risks explicitly identified and assessed in your institution's most recent BWRA?","AML/CFT BWRA","Other Risk Assessment Process"]
[null,"Money laundering","AJE","BGX"]
[null,"Terrorist financing ","AJF","BGY"]
[null,"Circumvention of sanctions regulations ","AJG","BGZ"]
[null,"Corruption (bribery)","AJH","BHA"]
[null,"Conflicts of interests ","AJI","BHB"]
[null,"Evasion of tax regulations ","AJJ","BHC"]
[null,"Internal fraud and embezzlement (by employees/management of your institution) ","AJK","BHD"]
[null,"External fraud and embezzlement (by customers or other business relations)","AJL","BHE"]
[null,"Cybercrime/ Ransomware","AJM","BHF"]
[null,"Market abuse","AJN","BHG"]
[null,"Customer groups","AJX","BHH"]
[null,"Geographies","AJY","BHI"]
[null,"Product groups","AJZ","BHJ"]
[null,"Distribution channels","AKA","BHK"]
[null,"Cryptos","AKC","BHL"]
[null,"Other","AJO"]
[null,"Where you answered yes to 'Other', please provide more detail.","AJP"]
[]
[null,"Are the outcomes of the BWRA considered in the following processes and activities?"]
[null,"Determining/adjusting the risk appetite","AJQ"]
[null,"Policy and procedures","AJR"]
[null,"New products and services","AJS"]
[null,"Setting scenarios and business rules for transaction monitoring","AJT"]
[null,"Other","AJU"]
[null,"Where you answered yes to 'other', please describe the other processes and activities in which you use the outcomes of the BWRA.","AJV"]
[]
[null,"Does your institution formulate a BWRA risk appetite?","AJW",null,"            "]
[]
[]
["8.4.2","Policies and Procedures"]
[]
[null,"Date(s) when the last version of the following policies and procedures approved by the management:"]
[null,"Customer onboarding","AKF"]
[null,"Ongoing Customer Due Diligence","AKG"]
[null,"Customer Offboarding","AKH"]
[null,"Politically Exposed Persons","AKI"]
[null,"High risk customers","AKJ"]
[null,"Transaction monitoring","AKK"]
[null,"Suspicious transaction reporting","AKL"]
[null,"Evasion of tax regulations","AKM"]
[null,"Ongoing monitoring of business relationships","AKN"]
[null,"Bribery","AKP"]
[null,"Conflicts of interest","AKQ"]
[null,"Fraud within or outside the organisation","AKR"]
[null,"Sanctions screening","AKS"]
[null,"Sanction hits handling","AKT"]
[null,"Sanction hits reporting - i.e. Financial Intelligence Unit; Revenue","AKU"]
[null,"Treating and reporting of ML/TF & Financial Sanctions incidents","AKV"]
[null,"Whistleblowing","AKW"]
[null,"Compliance function","AKX"]
[null,"Internal Audit/Assurance Testing","AKY"]
[null,"Separation of functions (Three Lines of Defence)","AKZ"]
[null,"Training","ALA"]
[null,"Geographic Risk Factors","ALB"]
[null,"AML/CFT Record Keeping","ALC"]
[null,"Business wide risk assessment process","ABB"]
[null,"Customer risk assessment process","ABC"]
[null,"Correspondent relationships","ABD"]
[null,"Identifying, and where relevant, updating policies, procedures and internal processes on foot of legislative changes/regulatory guidance.","ABE"]
[]
[null,"How often does your institution review/update your institution's AML/CFT policies and procedures","ALD"]
[]
["8.4.3","Onboarding"]
[]
[null,"What on-boarding options do your institution's customers have, according to your institution's policy?","Natural person customers","Legal entity customers"]
[null,"Internet / Email","ALE","ALK"]
[null,"App","ALF","ALL"]
[null,"Counter/Desk i.e. face to face","ALG","ALM"]
[null,"Third party","ALH","ALN"]
[null,"Other","ALI","ALO"]
[null,"Where you answered yes to 'other', specify other on-boarding options","ALJ","ALP"]
[]
[null,"Does your institution have policies and procedures in place defining which data is considered adequate for correctly establishing and verifying a customer's identity in the remote onboarding process (i.e. options above excluding 'counter/desk')?","ALQ"]
[null,"Does the onboarding process include specific questions aimed at identifying the intended purpose and nature of the business relationship?","ALR"]
[null,"If yes, please specify these questions.","ALS"]
[null,"Does your institution define customer groups that are excluded from the remote onboarding process?","ALT"]
[null,"If yes, please specify","ALU"]
[]
[null,"In your institution's remote on-boarding process, what is the procedure for verifying identity in accordance with your institution's policy","Natural person customers","Legal entity customers","Representatives","Beneficial Owners"]
[null,"Indirect identification by a nominal amount e.g. EUR 1.00/0.01 transfer from an Irish bank account in the customer's own name","ALV"]
[null,"Indirect identification by a nominal amount e.g. EUR 1.00/0.01 transfer from a foreign bank account in the customer's own name","ALW"]
[null,"Uploading a photo or photocopy of the customer's ID document","ALX",null,"AML"]
[null,"Scan of ID document and image of the customer to be authenticated by a natural person","ALY",null,"AMM"]
[null,"Uploading a photo of a bank account statement, salary slip or other documents with the customer's proof of address","ALZ",null,"AMN"]
[null,"Scan of ID documents (e.g. ePassports with NFC chip) with a chip device","AMA",null,"AMO"]
[null,"Request for passport details in online application form","AMB",null,"AMP"]
[null,"Verification of the customer's identity at the counter/desk","AMC",null,"AMQ"]
[null,"Other human intervention","AMD","AMH","AMR","AMV"]
[null,"Where you answered yes to 'other human intervention', please describe the method of other human intervention.","AME","AMI","AMS","AMW"]
[null,"Other","AMF","AMJ","AMT","AMX"]
[null,"Where you answered yes to 'other', please specify","AMG","AMK","AMU","AMY"]
[]
[]
["8.4.4","Offboarding"]
[]
[null,"State the total number of customers whose business relationships with your institution were terminated in the preceding calendar year due to AML/CFT/FS risks/concerns.","AMZ"]
[null,"of which were due to money laundering or related risks/concerns","ANA"]
[null,"of which were due to terrorist financing or related risks/concerns","ANB"]
[null,"of which were due to financial sanctions or related risks/concerns","ANC"]
[null,"of which were rated high risk as per your institution's CDD process prior to offboarding","AND"]
[]
[]
["8.4.5","Customer Due Diligence"]
[]
[null,"As part of your institution's Customer Risk Assessment process, what is assessed and recorded in a risk profile prior to providing services?","Natural person customers","Legal entity customers"]
[null,"Does this include verifying the identity of the customer?","ANE","ANF"]
[null,"Does this include establishing and verifying the identity of the beneficial owner?",null,"ANG"]
[null,"Are ownership and / or control structure identified?",null,"ANH"]
[null,"Does this include establishing the purpose and intended nature of the business relationship?","ANI","ANJ"]
[null,"Are source / origin of the funds / assets identified?","ANK","ANL"]
[null,"Does this include identifying the customer's representatives?","ANM","ANN"]
[null,"Are tax motives identified?","ANO","ANP"]
[null,"Are the geographies involved identified?","ANQ","ANR"]
[null,"Are intragroup activities identified?",null,"ANS"]
[null,"Are intragroup transactions identified?",null,"ANT"]
[]
[null,null,"Natural person customers","Legal entity customers"]
[null,"Does your institution periodically review its customers' risk profiles? For each of the risk categories below, state the frequency of these reviews","ANU","ANV"]
[null,"State the frequency of these reviews for each risk category"]
[null,"Low-risk customers","ANW","ANX"]
[null,"Medium-risk customers","ANY","ANZ"]
[null,"High-risk customers","AOA","AOB"]
[null,"PEPs","AOC"]
[null,"Unacceptable-risk customers (yet to be exited)","AOD","AOE"]
[]
[null,"Date when your institution assessed the need to update the customer risk assessment (CRA) for the last time","BFO"]
[]
[null,"Specify the number of customers per risk category:"]
[null,"Low risk customers","BFP"]
[null,"Medium-low risk customers","BFQ"]
[null,"Medium-high risk customers","BFR"]
[null,"High risk customers","BFS"]
[]
[null,null,"Natural person customers","Legal entity customers"]
[null,"Number of customers for whom updates of customer information were due in the preceding calendar year, in accordance with your institution's policies and procedures","BJU","BJV"]
[null,"Number of customers for whom customer information was reviewed and updated in the preceding calendar year","BGM","BGN"]
[]
[null,"Specify the proportion of backlog per customer risk category:","Natural person customers","Legal entity customers"]
[null,"Total customers","AOJ","AOK"]
[null,"High-risk customers","AOL","AOM"]
[null,"PEPs","AON"]
[null,"Unacceptable-risk customers (yet to be exited)","AOO","AOP"]
[]
[null,"Has your institution drawn up a plan with concrete timelines to address its periodic review backlogs?","AOQ","AOR"]
[]
[null,"With respect to each customer risk level, what proportion of active customers have incomplete or no CDD documentation/information","No identification/verification","Incomplete identification/verification"]
[null,"Total customers","BHM","AOT"]
[null,"High-risk Customers","BHN","AOU"]
[null,"PEPs","BHO","AOV"]
[]
[null,"Number of customers that are legal entities /trusts whose beneficial owners have not been identified","BFT"]
[null,"Number of high-risk customers that are legal entities /trusts whose beneficial ownership has been identified, but the identity of whom has not been verified","BFU"]
[null,"Number of customers for whom no information on the purpose and intended nature of the business relationship has been obtained (excluding customers with whom the obliged entity does not have a business relationship)","BFW"]
[null,"Number of customers for whom no information has been obtained on the nature of the customers’ business, or of their employment or occupation (excluding customers with whom the obliged entity does not have a business relationship)","BFX"]
[null,"Number of customers (excluding natural persons) for whom beneficial ownership identification details are entered in the institution's database","BFY"]
[null,"Number of customers, who are natural persons, for whom all identification details (name/ dob, nationality, tax number) are entered in the institution's database","BFZ"]
[]
[]
["8.4.6","Transaction Monitoring"]
[]
[null,"Does your institution draw up a transaction profile for customers at the initiation of services?","AOW"]
[null,"What is the frequency of review of the transaction profile?","AOX"]
[null,null,"Does your institution include the following aspects/elements in an expected transaction profile?","If your transaction monitoring system is automatic, can it generate alerts in case of inconsistencies between Customer Risk Assessment information relating to the customer and the following aspects/elements?"]
[null,"Number of transactions","AOY","BIC"]
[null,"Value of aggregated transactions","AOZ","BID"]
[null,"Value of single transactions","APA","BIE"]
[null,"Counterparties","APB","BIF"]
[null,"Geographies","APC","BIG"]
[null,"Intra-group transactions","APD","BIH"]
[null,"Banks/Payment Institutions involved","APE","BII"]
[]
[null,"State whether your institution monitors transactions and how this is done.","APF"]
[null,"If your institution uses an automated transaction monitoring system, was a model validation performed?","APG"]
[null,"Does your institution use technologies such as artificial intelligence and/or machine learning in its transaction monitoring process?","APH"]
[]
[null,"Does your institution use rules in its transaction monitoring process?","API"]
[null,"Does your institution have rules in its transaction monitoring process with respect to the following topics?"]
[null,"High-risk Geographies","APJ"]
[null,"Offshore jurisdictions","APK"]
[null,"Customer segments (any internal definition of customer groupings, retail or corporate customers, risk levels, associated sector, high value customer etc.)","APL"]
[null,"Sectors","APM"]
[null,"PEPs ","APN"]
[null,"Cash transactions","APO"]
[null,"Characteristics of transactions in text fields","APP"]
[null,"Customers with complex structures","APQ"]
[null,"Banks/Payment Institutions involved","APR"]
[null,"Other","APS"]
[null,"If you answered yes to \"Other\", please explain which topics/scenarios your rules cover","APT"]
[]
[null,"Does your institution periodically review its business rules in its transaction monitoring process?","APU"]
[null,"If so, what was the date of the most recent review?","APV"]
[null,"Did the most recent review lead to any changes in business rules?","APW"]
[null,"State whether detection of (possible) suspicious financial transactions takes place in real time or post-event.","APX"]
[]
[null,"How many transactions did your institution reject on the basis of insufficient information* about the payer or the payee in the preceding calendar year?\n*Information as referred to in Regulation (EU) 2023/1113 on information accompanying transfers of funds and certain crypto assets.","APY"]
[]
[]
["8.4.7","Alerts (in the preceding calendar year)"]
[null,"Answer the following questions with regard to your institution's Automated and/or Manual transaction monitoring systems","Automated","Manual"]
[null,"How many business decision rules were in place in your institution's transaction monitoring system in the preceding calendar year?","APZ","BDW"]
[null,"How many alerts were generated by the transaction monitoring system in the preceding calendar year?","AQA","BDX"]
[null,"What is the proportion of transaction monitoring alerts to total transactions?","AQB","BDY"]
[null,"How many alerts were investigated by an AML/transaction monitoring staff member?","AQD","BDZ"]
[null,"How many alerts were subject to escalation as true positives, i.e. reported as an STR?","AQE","BEA"]
[null,"How many alerts were closed as false positives following investigation?","AQF","BEB"]
[]
[null,null,"Automated","Manual"]
[null,"How many true positive hits have led to an event-driven review?","AQG","BHP"]
[null,"How many alerts were outstanding at the end of the year?","AQH","BHQ"]
[null,"From the initial alert generation, what is the average time in days taken to close a true positive alert?","AQI","BHR"]
[null,"What was the longest time in days taken to close a true positive alert in the preceding calendar year?","AQJ","BHS"]
[null,"If automated system: Ratio between number of STRs and number of alerts","BGA"]
[null,"If manual system, does the annual number of transactions exceed the number of transactions that the obliged entity can manually process?",null,"BGB"]
[null,"If manual system: Average time in days to analyse the transaction since the moment it occurred",null,"BGC"]
[]
["8.4.8","Suspicious Alerts and Transaction Rejections","\n"]
[null,"With reference to the total number of transaction monitoring alerts generated by the transaction monitoring system in the preceding calendar year, all questions in this section must be completed to confirm\n1. How many of those transaction alerts were due to each of the risk scenarios listed \n2. How many of those transactions were rejected on the grounds of the risk scenario listed\n"]
[null,"Alert type","No. Transaction Alerts","No. Transactions Rejected"]
[null,"AQK","AQL","AQM"]
[null,"Alert_total","< enter number >","< enter number >"]
[null,"Alert_ML","< enter number >","< enter number >"]
[null,"Alert_SR","< enter number >","< enter number >"]
[null,"Alert_fraud","< enter number >","< enter number >"]
[null,"Alert_TF","< enter number >","< enter number >"]
[]
["8.4.9","Suspicious Transaction Reporting"]
[null,"Is your institution registered with the Financial Intelligence Unit GoAML system and with Revenue for the purpose of reporting STRs","AQP"]
[]
[null,null,"Number of Notification","Number of Suspicious Transactions"]
[null,"How many suspicious transaction reports, and number of suspicious transactions therein, were reported in the preceding calendar year based on\n(note: an STR can contain multiple transactions)","AQR","AQS"]
[null,"Bribery/Corruption","AQV","AQW"]
[null,"Human trafficking","AQZ","ARA"]
[null,"Left wing extremism","ARD","ARE"]
[null,"Migrant smuggling","ARH","ARI"]
[null,"Money laundering","ARL","ARM"]
[null,"Politically exposed person","ARP","ARQ"]
[null,"Right wing extremism","ART","ARU"]
[null,"Sanctions list match","ARX","ARY"]
[null,"Sexual exploitation","ASB","ASC"]
[null,"Social welfare fraud","ASF","ASG"]
[null,"Tax evasion","ASJ","ASK"]
[null,"Terrorist financing","ASN","ASO"]
[null,"Trade based money laundering","ASR","BME"]
[]
[null,"Average number of days between the date of identification of potential suspicious transactions (prior to the analysis of the transaction) and the date when the transaction is reported to the FIU (after the analysis of the transaction) during the preceding calendar year","BGK"]
[null,"Number of STRs submitted to the FIU before the completion of the transaction during the preceding calendar year","BGL"]
[]
[]
["8.4.10","Sanctions Screening"]
[]
[null,"State whether your institution verifies, prior to providing services, whether or not customers or potential customers and their beneficial owners are included on sanctions lists.","ASV"]
[null,"State the average number of hours between the publication of the Targeted Financial Sanctions (TFS) by the authorities and the implementation of these changes in your institution's screening tools","BGD"]
[null,"State the maximum number of hours between the publication of the Targeted Financial Sanctions (TFS) by the authorities and the implementation of these changes in your institution's screening tools","BGE"]
[]
[null,"Specify the sanctions lists against which customers and beneficial owners are checked:"]
[null,"EU sanctions lists","ASX"]
[null,"National sanctions lists (e.g. UK OFSI, US OFAC)","ASW"]
[null,"UN lists","ASZ"]
[null,"Other","ATA"]
[null,"Where you answered yes to 'other', please specify","ATB"]
[]
[null,"State whether your institution verifies, at and after the start of service provision, whether a customer and its beneficial owners are included on sanctions lists. How often do you perform these checks?\nSelect all options, multiple answers are possible.","Check (y/n)","Frequency (no. check per year)"]
[null,"Checked when executing a transaction","ATC"]
[null,"Checked when sanctions listing updated","ATD"]
[null,"Periodic check of customers","ATE","ATF"]
[null,"Periodic check of beneficial owners connected to customers","ATG","ATH"]
[null,"Periodic check of representatives connected to customers","ATI","ATJ"]
[]
[null,"State the number of true positive hits that the sanctions list screening delivered in the preceding calendar year.","ATK"]
[null,"What the total value (EUR) of frozen assets recorded in relation to those true positive hits that the sanctions list screening delivered in the preceding calendar year.","ATL"]
[]
[]
["8.4.11","Outsourcing"]
[]
[null,"State whether the following processes (or parts thereof) have been outsourced to third parties (including within the Group)"]
[null,"Customer Risk Assessment - customer acceptance","ATU"]
[null,"Customer Risk Assessment - periodic customer review","ATV"]
[null,"Transaction monitoring","ATW"]
[null,"Alerts processing","ATX"]
[null,"Reporting of suspicious transactions","ATY"]
[null,"Sanctions screening","ATZ"]
[null,"Customer data management (for example storage in the cloud)","AUB"]
[null,"Training","BIV"]
[null,"PEP Detection","BIW"]
[null,"Compliance Monitoring Checks","BIX"]
[null,"Other processes related to risk management with regard to anti-money laundering and the countering of terrorist financing and proliferation financing","AUC"]
[null," - if 'other', please specify","AUD"]
[]
[null,"State the proportion of outsourced AML/CFT tasks where your institution incorporates compliance requirements with respect to financial crime legislation within its outsourcing agreements (e.g. Criminal Justice Act).","AUE"]
[null,"How does your institution ensure outsource provider compliance with the requirements"]
[null," - via reporting obligation","AUG"]
[null," - via training","AUH"]
[null," - via audit rights","AUJ"]
[null," - via other measures","AUK"]
[]
["8.4.12","Education & Training"]
[]
[null,"State the proportion of your institution's employees who attended training with regard to financial crime in the preceding calendar year and the average number of hours of AML training attended","Average number of hours of AML training in the preceding calendar year attended by (per person):","Proportion staff coverage in preceding calendar year"]
[null,"Non-AML/CFT specialist staff (customer facing staff, executive directors)","AUL","AUS"]
[null,"AML Specialist staff","AUM","AUT"]
[null,"Agents and distributors","AUN","AUU"]
[null,"Board members & non-executive directors","AUQ","AUX"]
[null,"Other","AUR","AUY"]
[]
[null,"Proportion of staff or trainees for whom at least one training was validated by a test","BFN"]
[]
[null,"The total number of full-time equivalent employees employed by your institution","BIL"]
[]
["8.4.13","Compliance & Assurance Testing"]
[]
[null,"Dates when the AML/CFT obligations/ controls were last assessed by your institution's compliance function:","Answer","Material Finding/Potential Breach Description "]
[null,"Business-wide risk assessment","AUZ","AVF"]
[null,"AML/CFT-related awareness-raising and staff training measures","AVA","AVG"]
[null,"Identification and identity verification procedures","AVB","AVH"]
[null,"Compliance with sanctions regulation","AVC","AVI"]
[null,"Resources dedicated to AML/CFT","AVD","AVJ"]
[null,"Organisation of the AML/CFT system, governance and reporting to management bodies.","AVE","AVK"]
[null,"Determination of ML/TF risk profile of customers in a business relationship","AVL","AVS"]
[null,"Policies and procedures for monitoring and analysing business relationships, including transaction monitoring","AVM","AVT"]
[null,"Policies and procedures for suspicious transaction reporting","AVN","AVU"]
[null,"Record keeping policies and procedures","AVO","AVV"]
[null,"Outsourcing arrangements","AVP","AVW"]
[null,"Other Financial Crime topics or processes","AVQ"]
[null,"Where you answered yes to 'Other' please specify","AVR","AVX"]
[]
[null,null,"Senior Management","Board"]
[null,"What is the frequency of compliance function reporting (i.e. financial crime, AML, sanctions) to senior management (ExCo.) and board?","AWG","AWH"]
[]
[null,"Number of dedicated AML/CFT compliance staff (in FTE)","BFM"]
[]
["8.4.14","Audit"]
[]
[null,"Dates when the AML/CFT obligations/ controls were last assessed by an internal audit or external expert:","Answer","Material Finding/Potential Breach Description "]
[null,"Business-wide risk assessment","AWW","AWX"]
[null,"AML/CFT-related awareness-raising and staff training measures","AWK","AWL"]
[null,"Identification and identity verification procedures","AWM","AWN"]
[null,"Compliance with sanctions regulation","AWQ","AWR"]
[null,"Resources dedicated to AML/CFT","AWY","AWZ"]
[null,"Organisation of the AML/CFT system, governance and reporting to management bodies.","AXG","AXH"]
[null,"Determination of ML/TF risk profile of customers in a business relationship","AXA","AXB"]
[null,"Policies and procedures for monitoring and analysing business relationships, including transaction monitoring","AXC","AXD"]
[null,"Policies and procedures for suspicious transaction reporting","AXE","AXF"]
[null,"Record keeping policies and procedures","AWO","AWP"]
[null,"Outsourcing arrangements","AXI","AXJ"]
[null,"Other Financial Crime topics or processes","AXK"]
[null,"Where you answered yes to 'Other' please specify","AXL","AXM"]
[]
[null,null,"Senior Management","Board"]
[null,"What is the frequency of audit function reporting (i.e. financial crime, AML, sanctions) to senior management (ExCo.) and board?","AXV","AXW"]
[]
[null,"State whether a foreign supervisory authority issued findings on your institution's risk management in the preceding calendar year. ","Yes/No","Finding Description"]
[null,"Money laundering","AYE","AAU"]
[null,"Terrorist financing ","AYF","AAV"]
[null,"Fund Transfer Regulation","AYG","AAW"]
[null,"Circumvention of sanctions","AYH","AAX"]
[null,"Corruption (bribery) and Conflicts of interests ","AYI","AAY"]
[null,"Other","AYJ"]
[null,"Where you answered yes to 'Other' please specify.","AYK","AAZ"]
[]
["8.4.15","Internal controls and reporting systems "]
[]
[null,"Date when the most recent reports on the following AML/CFT aspects have been submitted to the senior management"]
[null,"The areas where the operation of AML/CFT controls should be implemented or improved and suggested improvements","BEY"]
[null,"Compliance monitoring actions and a plan of activities of AML/CFT compliance officer","BEZ"]
[null,"A progress report of any significant remedial programmes","BFA"]
[null,"Adequacy of the human and technical resources in the AML/CFT compliance function","BFB"]
[null,"The main findings of the business-wide ML/TF risk assessment","BFC"]
[null,"Changes in the methodology for assessing customer risk profiles","BFD"]
[null,"The classification of customers by risk category","BFE"]
[null,"Statistical data on unusual and suspicious transactions","BFF"]
[null,"AML/CFT related findings of internal and external audits","BFG"]
[null,"AML/CFT training activities and plan.","BFH"]
[]
[null,"State the number of actions outstanding, and of which overdue, following the compliance checks as at calendar year-end","Outstanding","Overdue > 6 months"]
[null,"Total","AWA","AWE"]
[null,"Critical","AVY","AWC"]
[null,"High","AVZ","AWD"]
[]
["8.4.16","Governance"]
[]
[null,"State the frequency that the prevention of money laundering and terrorist financing was a regular reporting item on the agenda at Senior Management / Management Body meetings and Board meetings in the preceding calendar year.\nSelect the appropriate answer for each item.","Senior Management","Board"]
[null,"Money laundering","AYL","AYS"]
[null,"Terrorist financing ","AYM","AYT"]
[null,"Fund Transfer Regulation","AYN","AYU"]
[null,"Circumvention of sanctions","AYO","AYV"]
[null,"Corruption (bribery) and Conflicts of interests ","AYP","AYW"]
[]
[null,"Has your institution appointed a member of senior management with primary responsibility for implementing, managing and overseeing your institutions’ compliance with its AML/CFT obligations as required under Section 54(8) of the CJA 2010?","AYZ"]
[null,"Has your institution appointed an individual at management level (to be called a 'Compliance Officer') to monitor and manage compliance with, and the internal communication of, internal policies, controls and procedures adopted by your institution as required under Section 54(7) of the CJA 2010?","BIJ"]
[null,"How frequently has the Board been presented with a report (‘Compliance Officer Report’) from the compliance officer on your institution’s AML/CFT activities?","BIK"]
[null,"Have any AML/CFT /FS compliance shortcomings been reported to the Board in the preceding calendar year?","AZA"]
[null,"Where AML/CFT/FS compliance shortcomings have been reported, did the report set out remediation measures taken?","AZB"]
[null,"If Yes, briefly describe the reported AML/CFT/FS compliance shortcomings and related remediation measures taken.","AZC"]
[]
["8.4.17","Compliance with Fund Transfers Regulation"]
[null,"Number of outbound transfers for which requests were received from a counterparty in the transfer chain for information that is missing, incomplete or provided using inadmissible characters in the preceding calendar year","BGF"]
[null,"Total number of outbound transfers in the preceding calendar year","BGG"]
[null,"Proportion of outbound transfers rejected or returned by the counterparty in the transfer chain due to information that is missing, incomplete or provided using inadmissible characters in the preceding calendar year","BGH"]
[null,"Number of repeatedly failing counterparties flagged to the supervisor in the preceding calendar year","BGI"]
[null,"Total number of counterparties of outbound and inbound transfers in the preceding calendar year","BGJ"]

{"sheet":"8.5 Physical Presence","index":3,"n_rows":5,"n_cols":8,"rows_kept":5,"cut":false,"hidden":false,"merged":[[0,0,0,7]]}
["The questions below concern the institution being active through subsidiaries, branches, representative offices, and other physical presence.\n\nFor example: If your institution has one subsidiary in the UK, and one branch in France. You can report the first two rows: 1 - Select \"GB\" from the Country drop-down box and populate \"1\" under No. of subsidiaries and populate \"0\" under other column names; 2 - Select \"FR\" from the Country drop-down box and populate \"1\" under No. of branches and populate \"0\" under other column names."]
["Country","No. of subsidiaries","No. of branches","No. of representative offices","No. of other physical presences","No. of agents","No. of distributors","Number of white labelling partners"]
["AZD","AZE","AZF","AZG","AZH","BEV","BEW","BEX"]
["FR",0,1,0,0,0,0,0]
["GB",1,0,0,0,0,0,0]

{"sheet":"Drop-Downs","index":4,"n_rows":252,"n_cols":31,"rows_kept":252,"cut":false,"hidden":true,"merged":[]}
[null,"Yes/No",null,"Yes/No/NA",null,"Percentage 1",null,"Alpha2","CountryName",null,"Corporate Structure",null,"EEACountries",null,"County",null,"Segment","Explanation",null,"Sector","Explanation",null,"AlertType","Explaination",null,"TransactionLimitFreq",null,"BWRAConducted","Explanation",null,"EEACountriesNA"]
["< select answer >","Yes",null,"Yes",null,0,null,"00","NotApplicable",null,"Stand_alone_entity",null,"AT",null,"Carlow",null,"NP_physcially_on","Natural persons that were onboarded physically",null,"Mining","Mining (Raw materials & minerals)",null,"Alert_total","Total - all alerts",null,"Per_Transaction",null,"Yes","Yes",null,"00"]
["Yes","No",null,"No",null,"1% - 25%",null,"AD","Andorra",null,"Parent_of_group",null,"BE",null," Cavan",null,"NP_remotely_on","Natural persons that were onboarded remotely",null,"Oil_gas","Oil & Gas (onshore & offshore)",null,"Alert_ML","Money laundering",null,"Daily",null,"No","No",null,"AT"]
["No",null,null,"N/A",null,"26% - 50%",null,"AE","United Arab Emirates (the)",null,"Subsidiary_within_group",null,"BG",null," Clare",null,"NP_not_categorised","Natural persons that are not categorised as per CDD ratings",null,"Energy","Power / Energy (Production & Distribution)",null,"Alert_SR","Sanctions regulations",null,"Weekly",null,"Exemption_applies","Exemption applies from having in place the BWRA in accordance with Article 10(3) AMLR",null,"BE"]
["N/A",null,null,null,null,"51% - 75%",null,"AF","Afghanistan",null,"Branch_of_entity",null,"CY",null," Cork",null,"NP_blocked","Natural persons that are blocked/curtailed pending exit due to AML/CFT concerns",null,"Defence","Defence Industry, Military Goods (manufacturing, wholesale and retail)",null,"Alert_fraud","Fraud",null,"Monthly",null,null,null,null,"BG"]
[null,null,null,null,null,"76% - 100%",null,"AG","Antigua and Barbuda",null,null,null,"CZ",null," Donegal",null,"NP_suspended","Natural persons that are temporarily suspended (e.g., pending investigation outcome, document refresh, etc.)",null,"Precious_metal","Precious Metals, Stones and Jewellery Traders",null,"Alert_TF","Terrorist financing",null,"Quarterly",null,null,null,null,"CY"]
["< select answer >",null,null,null,null,null,null,"AI","Anguilla",null,null,null,"DE",null," Dublin",null,"NP_5000000","Natural persons that have total assets under management over a value of at least EUR 5,000,000",null,"Art_dealer","Art Dealers",null,null,null,null,"Yearly",null,null,null,null,"CZ"]
["every <1yr",null,null,null,null,null,null,"AL","Albania",null,null,null,"DK",null," Galway",null,"NP_50000000","Natural persons that have total assets over a value of at least EUR 50,000,000",null,"Crypto","Virtual Assets / Crytpo currency",null,null,null,null,"No_Limits",null,null,null,null,"DE"]
["every 1yr",null,null,null,null,null,null,"AM","Armenia",null,null,null,"EE",null," Kerry",null,"LE_physcially_on","Legal entities that are onboarded physically",null,"Gambling","Gambling",null,null,null,null,"Other",null,null,null,null,"DK"]
["every 2yrs ",null,null,null,null,null,null,"AO","Angola",null,null,null,"ES",null," Kildare",null,"LE_remotely_on","Legal entities that are onboarded remotely",null,"Contruction","Construction",null,null,null,null,null,null,null,null,null,"EE"]
["every 3yrs",null,null,null,null,null,null,"AQ","Antarctica",null,null,null,"FI",null," Kilkenny",null,"LE_not_categorised","Legal entities that are not categorised as per CDD ratings",null,"Real_estate","Real Estate",null,null,null,null,null,null,null,null,null,"ES"]
["every >3yrs",null,null,null,null,null,null,"AR","Argentina",null,null,null,"FR",null," Laois",null,"LE_blocked","Legal entities that are blocked/curtailed pending exit due to AML/CFT concerns",null,"TCSP","Trust or Company Service Providers (TCSPs)",null,null,null,null,null,null,null,null,null,"FI"]
[null,null,null,null,null,null,null,"AS","American Samoa",null,null,null,"GR",null," Leitrim",null,"LE_suspended","Legal entities that are temporarily suspended (e.g., pending investigation outcome, document refresh, etc.)",null,"Religion","Religious Institutions & Charities",null,null,null,null,null,null,null,null,null,"FR"]
[null,null,null,null,null,null,null,"AT","Austria",null,null,null,"HR",null," Limerick",null,"LE_SME","Legal Entities which are classified as Small/Medium enterprises (SMEs, as defined by the Department of Trade, Enterprise and Employment)",null,"Freight","Freight, Haulage & Shipping ",null,null,null,null,null,null,null,null,null,"GR"]
["< select answer >",null,null,null,null,null,null,"AU","Australia",null,null,null,"HU",null," Longford",null,"LE_corporate","Legal Entities that are corporate. ",null,"Advisory","Advisory & Consultancy Services",null,null,null,null,null,null,null,null,null,"HR"]
["Yes_in_all_cases",null,null,null,null,null,null,"AW","Aruba",null,null,null,"IS",null," Louth",null,"LE_TCSP","Legal Entities that  used TCSP services in the previous calendar year ",null,"IP","Intellectual Property / Patents Leasing",null,null,null,null,null,null,null,null,null,"HU"]
["Yes_only_in_enhanced_CDD_cases",null,null,null,null,null,null,"AX","Åland Islands",null,null,null,"IT",null," Mayo",null,"Private_banking","Private Banking customers ",null,"MTOPSP","Money Transfer Organisations and Payment Service Providers",null,null,null,null,null,null,null,null,null,"IS"]
["No",null,null,null,null,null,null,"AZ","Azerbaijan",null,null,null,"LI",null," Meath",null,"Complex","Customers with complex structures",null,"Pharm","Pharmaceuticals",null,null,null,null,null,null,null,null,null,"IT"]
[null,null,null,null,null,null,null,"BA","Bosnia and Herzegovina",null,null,null,"LT",null," Monaghan",null,"Cash_intensive","Customers that operate cash intensive businesses",null,"Scrap_dealer","Scrap Dealers",null,null,null,null,null,null,null,null,null,"LI"]
["< select answer >",null,null,null,null,null,null,"BB","Barbados",null,null,null,"LU",null," Offaly",null,"Shell_institution","Shell institutions",null,"Sale_motor","Sale of motor vehicles",null,null,null,null,null,null,null,null,null,"LT"]
["None",null,null,null,null,null,null,"BD","Bangladesh",null,null,null,"LV",null," Roscommon",null,"CASP","Crypto Asset Service Providers",null,"Sale_boat","Sale of boats",null,null,null,null,null,null,null,null,null,"LU"]
["Ad_hoc",null,null,null,null,null,null,"BE","Belgium",null,null,null,"MT",null," Sligo",null,"Credit_institution","Credit Institutions",null,"Catering","Catering",null,null,null,null,null,null,null,null,null,"LV"]
["Monthly",null,null,null,null,null,null,"BF","Burkina Faso",null,null,null,"NL",null," Tipperary",null,"Financial_institution","Financial Institutions (Non-Banking)",null,"Crowdfunding","Crowdfunding Service Providers",null,null,null,null,null,null,null,null,null,"MT"]
["Quarterly",null,null,null,null,null,null,"BG","Bulgaria",null,null,null,"NO",null," Waterford",null,"Government_body","Government bodies / State agencies",null,"Sport","Professional Sports",null,null,null,null,null,null,null,null,null,"NL"]
["Every_6_months",null,null,null,null,null,null,"BH","Bahrain",null,null,null,"PL",null," Westmeath",null,"SPV","Special Purpose Vehicles",null,"Stockbroker","Stock Brokers and Traders / Trading Platforms",null,null,null,null,null,null,null,null,null,"NO"]
["Yearly",null,null,">2years but <3 years",null,null,null,"BI","Burundi",null,null,null,"PT",null," Wexford",null,"NPO","Non-Profit Organisations",null,"Financial_service","Financial Services (not listed above)",null,null,null,null,null,null,null,null,null,"PL"]
["1_years-2_years ",null,null,null,null,null,null,"BJ","Benin",null,null,null,"RO",null," Wicklow",null,"NPO_non_EEA","Non-Profit Organisations with cross border transactions to/from non-EEA countries",null,"Other_high_risk","Other High Risk activities as per your institutions CRA’",null,null,null,null,null,null,null,null,null,"PT"]
["2_years-3_years",null,null,null,null,null,null,"BL","Saint Barthélemy",null,null,null,"SE",null,null,null,"Cust_non_EEA",null,null,"Other_sector","Other sectors",null,null,null,null,null,null,null,null,null,"RO"]
["3_years-4_years",null,null,null,null,null,null,"BM","Bermuda",null,null,null,"SI",null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,"SE"]
["4_years-5_years",null,null,null,null,null,null,"BN","Brunei Darussalam",null,null,null,"SK",null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,"SI"]
["Only_every_5_years_or_less",null,null,null,null,null,null,"BO","Bolivia (Plurinational State of)",null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,"SK"]
[null,null,null,null,null,null,null,"BQ","Bonaire, Sint Eustatius and Saba"]
[null,null,null,null,null,null,null,"BR","Brazil"]
[null,null,null,null,null,null,null,"BS","Bahamas (the)"]
[null,null,null,null,null,null,null,"BT","Bhutan"]
[null,null,null,null,null,null,null,"BV","Bouvet Island"]
[null,null,null,null,null,null,null,"BW","Botswana"]
[null,null,null,null,null,null,null,"BY","Belarus"]
[null,null,null,null,null,null,null,"BZ","Belize"]
["< select answer >",null,null,null,null,null,null,"CA","Canada"]
["no review",null,null,null,null,null,null,"CC","Cocos (Keeling) Islands (the)"]
["at least once a year",null,null,null,null,null,null,"CD","Congo (the Democratic Republic of the)"]
["once every two years",null,null,null,null,null,null,"CF","Central African Republic (the)"]
["once every three years",null,null,null,null,null,null,"CG","Congo (the)"]
["less than once every three years",null,null,null,null,null,null,"CH","Switzerland"]
["n/a",null,null,null,null,null,null,"CI","Côte d'Ivoire"]
[null,null,null,null,null,null,null,"CK","Cook Islands (the)"]
[null,null,null,null,null,null,null,"CL","Chile"]
["< select answer >",null,null,null,null,null,null,"CM","Cameroon"]
["yes",null,null,null,null,null,null,"CN","China"]
["no",null,null,null,null,null,null,"CO","Colombia"]
["n/a",null,null,null,null,null,null,"CR","Costa Rica"]
[null,null,null,null,null,null,null,"CU","Cuba"]
[null,null,null,null,null,null,null,"CV","Cabo Verde"]
["< select answer >",null,null,null,null,null,null,"CW","Curaçao"]
["Yes_manually",null,null,null,null,null,null,"CX","Christmas Island"]
["Yes_automatically",null,null,null,null,null,null,"CY","Cyprus"]
["Yes_manually_and_automatically",null,null,null,null,null,null,"CZ","Czechia"]
["No_transaction_monitoring",null,null,null,null,null,null,"DE","Germany"]
[null,null,null,null,null,null,null,"DJ","Djibouti"]
[null,null,null,null,null,null,null,"DK","Denmark"]
["Yes_quantitatively",null,null,null,null,null,null,"DM","Dominica"]
["Yes_qualitatively",null,null,null,null,null,null,"DO","Dominican Republic (the)"]
["Yes_quantitatively_and_qualitatively",null,null,null,null,null,null,"DZ","Algeria"]
["No",null,null,null,null,null,null,"EC","Ecuador"]
["N/A",null,null,null,null,null,null,"EE","Estonia"]
[null,null,null,null,null,null,null,"EG","Egypt"]
[null,null,null,null,null,null,null,"EH","Western Sahara"]
["< select answer >",null,null,null,null,null,null,"ER","Eritrea"]
[null,null,null,null,null,null,null,"ES","Spain"]
[null,null,null,null,null,null,null,"ET","Ethiopia"]
[null,null,null,null,null,null,null,"FI","Finland"]
[null,null,null,null,null,null,null,"FJ","Fiji"]
[null,null,null,null,null,null,null,"FK","Falkland Islands (the) [Malvinas]"]
[null,null,null,null,null,null,null,"FM","Micronesia (Federated States of)"]
["< select answer >",null,null,null,null,null,null,"FO","Faroe Islands (the)"]
["Real_time",null,null,null,null,null,null,"FR","France"]
["Post_event",null,null,null,null,null,null,"GA","Gabon"]
["Real_time_and_post_event",null,null,null,null,null,null,"GB","United Kingdom of Great Britain and Northern Ireland (the)"]
["No_detection",null,null,null,null,null,null,"GD","Grenada"]
[null,null,null,null,null,null,null,"GE","Georgia"]
[null,null,null,null,null,null,null,"GF","French Guiana"]
["< select answer >",null,null,null,null,null,null,"GG","Guernsey"]
["No",null,null,null,null,null,null,"GH","Ghana"]
["No_but_concrete_plans_to_source_in_future",null,null,null,null,null,null,"GI","Gibraltar"]
["Yes_entities_within_group",null,null,null,null,null,null,"GL","Greenland"]
["Yes_completely_or_partially_to_non_group_entities",null,null,null,null,null,null,"GM","Gambia (the)"]
[null,null,null,null,null,null,null,"GN","Guinea"]
[null,null,null,null,null,null,null,"GP","Guadeloupe"]
["< select answer >",null,null,null,null,null,null,"GQ","Equatorial Guinea"]
["yes",null,null,null,null,null,null,"GR","Greece"]
["no",null,null,null,null,null,null,"GS","South Georgia and the South Sandwich Islands"]
["n/a",null,null,null,null,null,null,"GT","Guatemala"]
[null,null,null,null,null,null,null,"GU","Guam"]
[null,null,null,null,null,null,null,"GW","Guinea-Bissau"]
["< select answer >",null,null,null,null,null,null,"GY","Guyana"]
["< 25%",null,null,null,null,null,null,"HK","Hong Kong"]
["25% - 50%",null,null,null,null,null,null,"HM","Heard Island and McDonald Islands"]
["50% - 75%",null,null,null,null,null,null,"HN","Honduras"]
["> 75%",null,null,null,null,null,null,"HR","Croatia"]
[null,null,null,null,null,null,null,"HT","Haiti"]
[null,null,null,null,null,null,null,"HU","Hungary"]
["< select answer >",null,null,null,null,null,null,"ID","Indonesia"]
["Yes_assessment_sufficient",null,null,null,null,null,null,"IE","Ireland"]
["Yes_assessment_sufficient_with_findings",null,null,null,null,null,null,"IL","Israel"]
["Yes_assessment_insufficient",null,null,null,null,null,null,"IM","Isle of Man"]
["No",null,null,null,null,null,null,"IN","India"]
[null,null,null,null,null,null,null,"IO","British Indian Ocean Territory (the)"]
[null,null,null,null,null,null,null,"IQ","Iraq"]
["< select answer >",null,null,null,null,null,null,"IR","Iran (Islamic Republic of)"]
["once every quarter or more often",null,null,null,null,null,null,"IS","Iceland"]
["once every six months",null,null,null,null,null,null,"IT","Italy"]
["once a year",null,null,null,null,null,null,"JE","Jersey"]
["less than once a year",null,null,null,null,null,null,"JM","Jamaica"]
["no reporting",null,null,null,null,null,null,"JO","Jordan"]
[null,null,null,null,null,null,null,"JP","Japan"]
[null,null,null,null,null,null,null,"KE","Kenya"]
["< select answer >",null,null,null,null,null,null,"KG","Kyrgyzstan"]
["yes",null,null,null,null,null,null,"KH","Cambodia"]
["no",null,null,null,null,null,null,"KI","Kiribati"]
["n/a",null,null,null,null,null,null,"KM","Comoros (the)"]
[null,null,null,null,null,null,null,"KN","Saint Kitts and Nevis"]
[null,null,null,null,null,null,null,"KP","Korea (the Democratic People's Republic of)"]
["< select answer >",null,null,null,null,null,null,"KR","Korea (the Republic of)"]
["not reported",null,null,null,null,null,null,"KW","Kuwait"]
["every meeting",null,null,null,null,null,null,"KY","Cayman Islands (the)"]
["monthly",null,null,null,null,null,null,"KZ","Kazakhstan"]
["quarterly",null,null,null,null,null,null,"LA","Lao People's Democratic Republic (the)"]
["half-yearly",null,null,null,null,null,null,"LB","Lebanon"]
["annually",null,null,null,null,null,null,"LC","Saint Lucia"]
[null,null,null,null,null,null,null,"LI","Liechtenstein"]
[null,null,null,null,null,null,null,"LK","Sri Lanka"]
["< select answer >",null,null,null,null,null,null,"LR","Liberia"]
["n/a my institution does not offer remote on-boarding",null,null,null,null,null,null,"LS","Lesotho"]
["yes",null,null,null,null,null,null,"LT","Lithuania"]
["no",null,null,null,null,null,null,"LU","Luxembourg"]
[null,null,null,null,null,null,null,"LV","Latvia"]
[null,null,null,null,null,null,null,"LY","Libya"]
["< select answer >",null,null,null,null,null,null,"MA","Morocco"]
["yes",null,null,null,null,null,null,"MC","Monaco"]
["no",null,null,null,null,null,null,"MD","Moldova (the Republic of)"]
["n/a",null,null,null,null,null,null,"ME","Montenegro"]
[null,null,null,null,null,null,null,"MF","Saint Martin (French part)"]
[null,null,null,null,null,null,null,"MG","Madagascar"]
[null,null,null,null,null,null,null,"MH","Marshall Islands (the)"]
[null,null,null,null,null,null,null,"MK","Republic of North Macedonia"]
[null,null,null,null,null,null,null,"ML","Mali"]
[null,null,null,null,null,null,null,"MM","Myanmar"]
[null,null,null,null,null,null,null,"MN","Mongolia"]
[null,null,null,null,null,null,null,"MO","Macao"]
[null,null,null,null,null,null,null,"MP","Northern Mariana Islands (the)"]
[null,null,null,null,null,null,null,"MQ","Martinique"]
[null,null,null,null,null,null,null,"MR","Mauritania"]
[null,null,null,null,null,null,null,"MS","Montserrat"]
[null,null,null,null,null,null,null,"MT","Malta"]
[null,null,null,null,null,null,null,"MU","Mauritius"]
[null,null,null,null,null,null,null,"MV","Maldives"]
[null,null,null,null,null,null,null,"MW","Malawi"]
[null,null,null,null,null,null,null,"MX","Mexico"]
[null,null,null,null,null,null,null,"MY","Malaysia"]
[null,null,null,null,null,null,null,"MZ","Mozambique"]
[null,null,null,null,null,null,null,"NA","Namibia"]
[null,null,null,null,null,null,null,"NC","New Caledonia"]
[null,null,null,null,null,null,null,"NE","Niger (the)"]
[null,null,null,null,null,null,null,"NF","Norfolk Island"]
[null,null,null,null,null,null,null,"NG","Nigeria"]
[null,null,null,null,null,null,null,"NI","Nicaragua"]
[null,null,null,null,null,null,null,"NL","Netherlands (the)"]
[null,null,null,null,null,null,null,"NO","Norway"]
[null,null,null,null,null,null,null,"NP","Nepal"]
[null,null,null,null,null,null,null,"NR","Nauru"]
[null,null,null,null,null,null,null,"NU","Niue"]
[null,null,null,null,null,null,null,"NZ","New Zealand"]
[null,null,null,null,null,null,null,"OM","Oman"]
[null,null,null,null,null,null,null,"PA","Panama"]
[null,null,null,null,null,null,null,"PE","Peru"]
[null,null,null,null,null,null,null,"PF","French Polynesia"]
[null,null,null,null,null,null,null,"PG","Papua New Guinea"]
[null,null,null,null,null,null,null,"PH","Philippines (the)"]
[null,null,null,null,null,null,null,"PK","Pakistan"]
[null,null,null,null,null,null,null,"PL","Poland"]
[null,null,null,null,null,null,null,"PM","Saint Pierre and Miquelon"]
[null,null,null,null,null,null,null,"PN","Pitcairn"]
[null,null,null,null,null,null,null,"PR","Puerto Rico"]
[null,null,null,null,null,null,null,"PS","Palestine, State of"]
[null,null,null,null,null,null,null,"PT","Portugal"]
[null,null,null,null,null,null,null,"PW","Palau"]
[null,null,null,null,null,null,null,"PY","Paraguay"]
[null,null,null,null,null,null,null,"QA","Qatar"]
[null,null,null,null,null,null,null,"RE","Réunion"]
[null,null,null,null,null,null,null,"RO","Romania"]
[null,null,null,null,null,null,null,"RS","Serbia"]
[null,null,null,null,null,null,null,"RU","Russian Federation (the)"]
[null,null,null,null,null,null,null,"RW","Rwanda"]
[null,null,null,null,null,null,null,"SA","Saudi Arabia"]
[null,null,null,null,null,null,null,"SB","Solomon Islands"]
[null,null,null,null,null,null,null,"SC","Seychelles"]
[null,null,null,null,null,null,null,"SD","Sudan (the)"]
[null,null,null,null,null,null,null,"SE","Sweden"]
[null,null,null,null,null,null,null,"SG","Singapore"]
[null,null,null,null,null,null,null,"SH","Saint Helena, Ascension and Tristan da Cunha"]
[null,null,null,null,null,null,null,"SI","Slovenia"]
[null,null,null,null,null,null,null,"SJ","Svalbard and Jan Mayen"]
[null,null,null,null,null,null,null,"SK","Slovakia"]
[null,null,null,null,null,null,null,"SL","Sierra Leone"]
[null,null,null,null,null,null,null,"SM","San Marino"]
[null,null,null,null,null,null,null,"SN","Senegal"]
[null,null,null,null,null,null,null,"SO","Somalia"]
[null,null,null,null,null,null,null,"SR","Suriname"]
[null,null,null,null,null,null,null,"SS","South Sudan"]
[null,null,null,null,null,null,null,"ST","Sao Tome and Principe"]
[null,null,null,null,null,null,null,"SV","El Salvador"]
[null,null,null,null,null,null,null,"SX","Sint Maarten (Dutch part)"]
[null,null,null,null,null,null,null,"SY","Syrian Arab Republic"]
[null,null,null,null,null,null,null,"SZ","Eswatini"]
[null,null,null,null,null,null,null,"TC","Turks and Caicos Islands (the)"]
[null,null,null,null,null,null,null,"TD","Chad"]
[null,null,null,null,null,null,null,"TF","French Southern Territories (the)"]
[null,null,null,null,null,null,null,"TG","Togo"]
[null,null,null,null,null,null,null,"TH","Thailand"]
[null,null,null,null,null,null,null,"TJ","Tajikistan"]
[null,null,null,null,null,null,null,"TK","Tokelau"]
[null,null,null,null,null,null,null,"TL","Timor-Leste"]
[null,null,null,null,null,null,null,"TM","Turkmenistan"]
[null,null,null,null,null,null,null,"TN","Tunisia"]
[null,null,null,null,null,null,null,"TO","Tonga"]
[null,null,null,null,null,null,null,"TR","Turkey"]
[null,null,null,null,null,null,null,"TT","Trinidad and Tobago"]
[null,null,null,null,null,null,null,"TV","Tuvalu"]
[null,null,null,null,null,null,null,"TW","Taiwan (Province of China)"]
[null,null,null,null,null,null,null,"TZ","Tanzania, United Republic of"]
[null,null,null,null,null,null,null,"UA","Ukraine"]
[null,null,null,null,null,null,null,"UG","Uganda"]
[null,null,null,null,null,null,null,"UM","United States Minor Outlying Islands (the)"]
[null,null,null,null,null,null,null,"US","United States of America (the)"]
[null,null,null,null,null,null,null,"UY","Uruguay"]
[null,null,null,null,null,null,null,"UZ","Uzbekistan"]
[null,null,null,null,null,null,null,"VA","Holy See (the)"]
[null,null,null,null,null,null,null,"VC","Saint Vincent and the Grenadines"]
[null,null,null,null,null,null,null,"VE","Venezuela (Bolivarian Republic of)"]
[null,null,null,null,null,null,null,"VG","Virgin Islands (British)"]
[null,null,null,null,null,null,null,"VI","Virgin Islands (U.S.)"]
[null,null,null,null,null,null,null,"VN","Viet Nam"]
[null,null,null,null,null,null,null,"VU","Vanuatu"]
[null,null,null,null,null,null,null,"WF","Wallis and Futuna"]
[null,null,null,null,null,null,null,"WS","Samoa"]
[null,null,null,null,null,null,null,"XK","Kosovo"]
[null,null,null,null,null,null,null,"YE","Yemen"]
[null,null,null,null,null,null,null,"YT","Mayotte"]
[null,null,null,null,null,null,null,"ZA","South Africa"]
[null,null,null,null,null,null,null,"ZM","Zambia"]
[null,null,null,null,null,null,null,"ZW","Zimbabwe"]

{"sheet":"8.6 Residence & Establishment","index":5,"n_rows":5,"n_cols":10,"rows_kept":5,"cut":false,"hidden":false,"merged":[[1,0,2,0],[1,5,1,9],[0,0,0,9]]}
["The questions below concern the institution's customer base.\n\nPlease specify the number of your customers who are legal entities residing or legal entities establishing in that country.\n\nFor example,\nif your institution has total 4 natural person customers in the UK, of which \n2 are new customers and also are PEPs, their family members or persons known to be close associates,\n1 is rated high risk; and\nif your institution has total 4 legal entity customers in the UK, of which\n1 is a new customer,\n2 is rated high risk,\nyou may select \"GB\" from the Country drop-down box and populate \"4\" under \"Total No.\" within \"Natural person customers\", populate \"2\" under \"No. of which are New Customers\" and \"No. of which are PEPs, their family members or persons known to be close associates\" within \"Natural person customers\", populate \"2\" under \"No. of which are High Risk\"; populate \"4\" under \"Total No.\" within \"Legal entity customers\", populate \"2\" under \"No. of which are High Risk\", and populate \"1\" under other column names."]
["Country","Natural person customers",null,null,null,"Legal entity customers"]
[null,"Total No.","No. of which are New Customers","No. of which are\nHigh Risk","No. of which are PEPs, \ntheir family members \nor persons known to be close associates","Total No.","No. of which are New Customers","No. of which are\nHigh Risk","No. of which are with at least one beneficial owner residing in non-EEA countries","No. of which have PEP Risk Identified"]
["AZI","AZJ","AZK","AZL","AZO","AZP","AZQ","AZR","AZU","ABA"]
["GB",4,2,2,2,4,1,2,1,1]

{"sheet":"8.7 Beneficial Owners","index":6,"n_rows":6,"n_cols":3,"rows_kept":6,"cut":false,"hidden":false,"merged":[[1,0,2,0],[0,0,0,2]]}
["The questions below concern the beneficial owners (BOs) in relation to your institution's customer base.\n\nPlease specify per country, the number of your legal entity customers' BOs, and of which are PEPs, who reside in that country.\n\nFor example, if 4 of your legal entity customers' BOs reside in the UK and 2 of them are PEPs, their familly members or persons known to be close associates,\nYou may select \"GB\" from the list of countries, populate \"4\" under \"Total No.\" within \"Legal entity customer's BOs\" and populate \"2\" under the other column name.\nIf 1 of your legal entity customers' BOs reside in Denmark and they have no associated PEPs then you may select \"DK\" from the list of countries, populate \"4\" under \"Total No.\" and 0 under the other column."]
["Country","Your legal entity customers' BOs"]
[null,"Total No.","No. of which are PEPs,\n their family members\nor persons known to be close associates"]
["AZV","AZW","AZX"]
["GB",4,2]
["DK",1,0]

{"sheet":"8.8 Payment Transactions","index":7,"n_rows":4,"n_cols":13,"rows_kept":4,"cut":false,"hidden":false,"merged":[[1,0,2,0],[0,0,0,12],[1,1,1,6],[1,7,1,12]]}
["The questions in this section only relate to non-cash transactions (payment transfers) between two bank accounts (customer-to-customer transfers). Debit/card payments and cash deposits/withdrawals should be excluded.\nSelect each country, to and from, which your institution provided or received payments transactions in the preceding calendar year stating for each country selected: \n• the total number of your customer accounts to which your institution provided payment transactions i) on an incoming basis and ii) on an outgoing basis in the preceding calendar year \n• the total number and value (EUR) of incoming and outgoing payment transactions in the preceding calendar year. \n\nThe country selected should be based on the country of the bank account from which payments originated (inward payments), or of the ultimate recipient bank account (outward payments), e.g. using the IBAN, BIC or Swift Code country of the bank account.\nThe total data by country provided should then be broken down to provide the number of high risk customer accounts through which those payments were processed.\n\n"]
["Country","Overall",null,null,null,null,null,"of which High Risk (per your Customer Risk Assessment)"]
[null,"No. of accounts\n(incoming)","No. of incoming transactions","Value of incoming transactions","No. of accounts\n(outgoing)","No. of outgoing transactions","Value of outgoing transactions","No. of accounts\n(incoming)","No. of incoming transactions","Value of incoming transactions","No. of accounts\n(outgoing)","No. of outgoing transactions","Value of outgoing transactions"]
["AZY","AZZ","BAA","BAB","BMF","BAC","BAD","BAE","BAF","BAG","BMG","BAH","BAI"]

{"sheet":"8.9 Pooled Accounts","index":8,"n_rows":4,"n_cols":11,"rows_kept":4,"cut":false,"hidden":false,"merged":[[0,0,0,10],[1,0,2,0]]}
["The following questions are related to pooled accounts, which are bank accounts opened by customers such as financial institutions,  legal practitioners or notaries to hold their clients' money. In these accounts, clients' money is comingled, but the clients cannot directly tell the bank to carry out transactions.\nPlease state the number of pooled accounts and subaccounts, the total number and value (EUR) of incoming and outgoing transactions per country. The country selected should be based on the country of the bank accounts used in the preceding calendar year, e.g. using the IBAN, BIC or Swift Code country of the bank account.\n"]
["Country","Overall",null,null,null,null,"of which High Risk (per your Institution's Customer Risk Assessment)"]
[null,"No. of pooled accounts and subaccounts","No. of incoming transactions","Value of incoming transactions","No. of outgoing transactions","Value of outgoing transactions","No. of pooled accounts and subaccounts","No. of incoming transactions","Value of incoming transactions","No. of outgoing transactions","Value of outgoing transactions"]
["BLA","BLB","BLC","BLD","BLE","BLF","BLG","BLH","BLI","BLJ","BLK"]

{"sheet":"8.10 Correspondent Relationship","index":9,"n_rows":4,"n_cols":11,"rows_kept":4,"cut":false,"hidden":false,"merged":[[0,0,0,10],[1,0,2,0]]}
["The questions below concern the correspondent relationship, where your institution is the correspondent.\n\nPlease state the number of institutions as the respondent to which your institution provides services as the correspondent and specify the total number and value (EUR) of incoming and outgoing transactions in the preceding calendar year."]
["Country","Overall",null,null,null,null,"of which High Risk (per your Institution's Customer Risk Assessment)"]
[null,"No. of respondent institutions","No. of incoming transactions","Value of incoming transactions","No. of outgoing transactions","Value of outgoing transactions","No. of respondent institutions","No. of incoming transactions","Value of incoming transactions","No. of outgoing transactions","Value of outgoing transactions"]
["BLL","BAT","BLM","BLN","BLO","BLP","BJW","BLQ","BLR","BLS","BLT"]

{"sheet":"8.11 Trade Finance","index":10,"n_rows":4,"n_cols":11,"rows_kept":4,"cut":false,"hidden":false,"merged":[[0,0,0,10],[1,0,2,0],[1,6,1,10]]}
["The questions below concern trade finance services to customers with importing or exporting activities.\n\nPlease state the number of customers to whom your institution provided trade finance in the preceding calendar year and specify the total number and value (EUR) of incoming and outgoing trade finance transactions in the preceding calendar year, based on the BICs (country codes) of the accounts used. The country selected should be based on the country of the bank account from which transactions originated (inward transactions), or of the ultimate recipient bank account (outward transactions), e.g. using the IBAN, BIC or Swift Code country of the bank account."]
["Country","Overall",null,null,null,null,"of which High Risk (per your Institution's Customer Risk Assessment)"]
[null,"No. of customers","No. of incoming transactions","Value of incoming transactions","No. of outgoing transactions","Value of outgoing transactions","No. of customers","No. of incoming transactions","Value of incoming transactions","No. of outgoing transactions","Value of outgoing transactions"]
["BLU","BAU","BLV","BLW","BLX","BLY","BLZ","BMA","BMB","BMC","BMD"]

{"sheet":"8.12 Geography of Funds Flow","index":11,"n_rows":4,"n_cols":13,"rows_kept":4,"cut":false,"hidden":false,"merged":[[1,0,2,0],[1,7,1,12],[0,0,0,12],[1,1,1,6]]}
["The questions below concern the source and destination of all funds flow transacted by your customers using your products or services,\ne.g. entry/exit points for deposits, payments, withdrawals, transfers, remittance, FX, value transfer/exchange etc.\nSpecify by country in terms of the source and destination of funds flow, using drop-down options, customer numbers, total transaction numbers and values (EUR) for that country for the prior calendar year.\n"]
["Country","Overall",null,null,null,null,null,"of which High Risk (per your Institution's Customer Risk Assessment)\n"]
[null,"No. of customers\n(Source)","No. of transactions\n(Source)","Value of transactions\n(Source)","No. of customers\n(Destination)","No. of transactions\n(Destination)","Value of transactions\n(Destination)","No. of customers\n(Source)","No. of transactions\n(Source)","Value of transactions\n(Source)","No. of customers\n(Destination)","No. of transactions\n(Destination)","Value of transactions\n(Destination)"]
["BDE","BDF","BDG","BDH","BDI","BDJ","BDK","BMH","BMI","BMJ","BMK","BDL","BDM"]

{"sheet":"8.13 Transaction Monitoring","index":12,"n_rows":5,"n_cols":5,"rows_kept":5,"cut":false,"hidden":false,"merged":[[0,0,0,4]]}
["In the below table we specifically refer to Transaction Monitoring Alerts.\n\nFor each Transaction Monitoring Rule/Model in your system, state the name of the rule/model, give a very brief description (see example), specify the number of alerts of this rule/model, number of true positive alerts and number of false positives alerts."]
["Rule Name / ID","High Level Rule / Model Description","Number of Transaction Monitoring Alerts for Rule/Model","Number of True Positive Alerts for Rule/Model","Number of False Positive Alerts for Rule/Model"]
["BDR","BDS","BDT","BDU","BDV"]
["R001_Foreign_Cash","Rule which detects significant cash deposit and subsequent risky international transaction",25,2,23]
["R002_Incoming_Smurfing","Detects large number of incoming small transactions from different sources, contrary to expected behaviour for customer segment",0,0,0]