FI Standard / FFI Procedure
What is four (4)?
Name 2 factors that affect FI EDD Level determination
What is FI Type, relationship type, liability account?
Sanctions Threshold Question must be answered by this individual
What is Customer representative?
What is non-trade SBLC?
Name 2 types of Triggers
Administrative and Material
Name and define the 2 relationship types
What is:
- Proprietary relationships: FI transacts on its own behalf with the Bank
- Third Party relationships: FI uses its accounts, products or services with the Bank for or on behalf of the FI’s own Customers
Determining factor for foreign vs domestic classification of an FI
Name the determining factors for an SPV’s classification of a NOAH
What is clear non-complex ownership with a clear business purpose and no third-party members/investors?
Name the TF requirements for Participations Bought
What is n/a - Participations Bought does not require trade finance additional due diligence?
Main factor for determining administrative vs material classification
What is a deposit, transactional or other account the Bank establishes to hold an FI Customer’s funds or assets. Examples:
1. DDA (Demand Deposit Account)
2. MMDA (Money-Market Deposit Account)
3. FCA (Foreign Currency Account)
FI Type for Insurance Company
What is FI Type 3 - lower risk non-bank financial institution
Name the reason for the On-boarding Unit’s 7 day split between 5 & 2 days
What is determining the root cause of the delay and number of times documentation is not provided in full
For scenario 1 (FI provides TF product to their Customers), name the 2 initial steps to be taken by the Onboarding Unit
What is:
1. Confirm that the entity has requested MUFG participation
2. Ensure the product applicability section in the Procedure applies
Number of days to analyze trigger event
30 days
Define a Financial Institution, including both criteria under MUFG’s definition
What are Bank or non-bank financial service providers that: (i)deals primarily with financial transactions such as deposits, loans, investments, payments, and currency exchange, or (ii) act as financial intermediaries
Describe the process for FI EDD determination, in the correct order
What is FI type, relationship type, Foreign or domestic status, and liability account? If applicable, what is CRR or Country Risk Rating
Name 2 relief on ownership that the procedure allows for, regarding drilldown
What is:
1. When a publicly listed entity is reached and the Customer is FinCEN Exempt, not drilling down into that line of ownership
2. When a Customer is ultimately majority or wholly owned by listed entities (MUFG approved exchanges included), intermediaries are not required
Name when Supply Chain Finance is not in scope for the additional requirements
What is when MUFG is a participant in another Bank Led SCF program
Describe how FinCEN Triggers fit into the trigger review process
What is, separate and apart from when a trigger is classified as admin or material, the OBU must analyze if the trigger also classifies as a FinCEN Trigger event.
Name all types of FIs and provide at least one example of each
What are 1. Public/Government FIs 2. Banks and Depository Institutions 3. Lower Risk NBFI 4. Higher Risk NBFI
What is Level 1 FI EDD
Name the new requirement introduced in Procedure v2.1 and some of its major elements
What is a business summary with the Customer overview, Customer Risk factors, and Adverse Media escalation, if any?
Describe the 3 scenarios for the Trade Finance Due Diligence requirements
What is 1. FI provides TF products to its Customers and requests MUFG participation 2. Corporate Customer or FI uses TF product for its own behalf 3. Both scenarios 1 & 2 - for which all trade finance requirements are applicable based on transaction purpose
Describe high level process for reviewing a trigger event