1. ENTITY & O W NERSHIP

1 Wolfsberg Group Correspondent Banking Due Diligence Questionnaire (CBDDQ) Institution Name:Location (Country) : The Wolfsberg Group 2020 Page 1 CBDDQ questionnaire is required to be answered on a Legal ENTITY (LE) Level. The Financial Institution should answer the questionnaire at the legal entitylevel including any branches for which the client base, products and control model are materially similar to the LE Head Office. This questionnaire should not cover more than one LE. Each question in the CBDDQ will need to be addressed from the perspective of the LE and on behalf of all of its branches. If a response for the LE differs for one of its branches, this needs to be highlighted and details regarding this difference captured at the end of each sub-section. If a branch's business activity (products offered, client base etc.) is materially different than its ENTITY Head Office, a separate questionnaire can be completed for that #QuestionAnswer1.

2 ENTITY & OWNERSHIP1 Full Legal Name2 Append a list of foreign branches which arecovered by this questionnaire3 Full Legal (Registered) Address4 Full Primary Business Address (if different fromabove)5 Date of ENTITY incorporation/ establishment6 Select type of ownership and append anownership chart if available6 aPublicly Traded (25% of shares publicly traded)6 a1If Y, indicate the exchange traded on and tickersymbol6 bMember Owned/ Mutual6 cGovernment or State Owned by 25% or more6 dPrivately Owned6 d1If Y, provide details of shareholders or ultimatebeneficial owners with a holding of 10% or more7% of the ENTITY 's total shares composed ofbearer shares8 Does the ENTITY , or any of its branches, operateunder an Offshore Banking License (OBL) ?8 aIf Y, provide the name of the relevant branch/eswhich operate under an OBL9 Name of primary financial regulator / supervisoryauthorityWolfsberg Group Correspondent Banking Due Diligence Questionnaire (CBDDQ) The Wolfsberg Group 2020 Page 2 CBDDQ Legal ENTITY Identifier (LEI) if available11 Provide the full legal name of the ultimate parent(if different from the ENTITY completing the DDQ)12 Jurisdiction of licensing authority and regulatorof ultimate parent13 Select the business areas applicable to theEntity13 aRetail Banking13 bPrivate Banking / Wealth Management13 cCommercial Banking13 dTransactional Banking13 eInvestment Banking13 fFinancial Markets Trading13 gSecurities Services / Custody13 hBroker / Dealer13 iMultilateral Development Bank13 jOther14 Does the ENTITY have a significant (10% or more)portfolio of non-resident customers or does it derive more than 10% of its revenue from non- resident customers?

3 (Non-resident means customers primarily resident in a different jurisdiction to the location where bank services are provided.)14 aIf Y, provide the top five countries where the non-resident customers are the closest value:15 aNumber of employees15 bTotal Assets16 Confirm that all responses provided in the aboveSection ENTITY & OWNERSHIP are representative of all the LE's branches16 aIf N, clarify which questions the difference/srelate to and the branch/es that this applies bIf appropriate, provide any additional information/ context to the answers in this Group Correspondent Banking Due Diligence Questionnaire (CBDDQ) The Wolfsberg Group 2020 Page 3 CBDDQ PRODUCTS & SERVICES17 Does the ENTITY offer the following products andservices:17 aCorrespondent Banking17 a1If Y17 a2 Does the ENTITY offer Correspondent Bankingservices to domestic banks?17 a3 Does the ENTITY allow domestic bank clients toprovide downstream relationships?17 a4 Does the ENTITY have processes and proceduresin place to identify downstream relationships with domestic banks?

4 17 a5 Does the ENTITY offer correspondent bankingservices to Foreign Banks?17 a6 Does the ENTITY allow downstream relationshipswith Foreign Banks?17 a7 Does the ENTITY have processes and proceduresin place to identify downstream relationships with Foreign Banks?17 a8 Does the ENTITY offer correspondent bankingservices to regulated MSBs/MVTS?17 a9 Does the ENTITY allow downstream relationshipswith MSBs/MVTS?17 a10 Does the ENTITY have processes and proceduresin place to identify downstream relationships with MSB /MVTS?17 bPrivate Banking (domestic & international)17 cTrade Finance17 dPayable Through Accounts17 eStored Value Instruments17 fCross Border Bulk Cash Delivery17 gDomestic Bulk Cash Delivery17 hInternational Cash Letter17 iRemote Deposit Capture17 jVirtual /Digital Currencies17 kLow Price Securities17 lHold Mail17 mCross Border Remittances17 nService to walk-in customers (non-accountholders)17 oSponsoring Private ATMs17 pOther high risk products and services identifiedby the Entity18 Confirm that all responses provided in the aboveSection PRODUCTS & SERVICES are representative of all the LE's branches18 aIf N, clarify which questions the difference/srelate to and the branch/es that this applies bIf appropriate, provide any additional information/ context to the answers in this Group Correspondent Banking Due Diligence Questionnaire (CBDDQ)

5 The Wolfsberg Group 2020 Page 4 CBDDQ AML, CTF & SANCTIONS PROGRAMME19 Does the ENTITY have a programme that setsminimum AML, CTF and Sanctions standards regarding the following components:19 aAppointed Officer with sufficientexperience/expertise19 bCash Reporting19 cCDD19 dEDD19 eBeneficial Ownership19 fIndependent Testing19 gPeriodic Review19 hPolicies and Procedures19 iRisk Assessment19 jSanctions19 kPEP Screening19 lAdverse Information Screening19 mSuspicious Activity Reporting19 nTraining and Education19 oTransaction Monitoring20 How many full time employees are in the ENTITY 'sAML, CTF & Sanctions Compliance Department?21Is the ENTITY 's AML, CTF & Sanctions policyapproved at least annually by the Board or equivalent Senior Management Committee?22 Does the Board or equivalent SeniorManagement Committee receive regular reporting on the status of the AML, CTF & Sanctions programme?23 Does the ENTITY use third parties to carry out anycomponents of its AML, CTF & Sanctions programme?

6 23 aIf Y, provide further details24 Confirm that all responses provided in the aboveSection AML, CTF & SANCTIONS Programme are representative of all the LE's branches24 aIf N, clarify which questions the difference/srelate to and the branch/es that this applies bIf appropriate, provide any additional information/ context to the answers in this Group Correspondent Banking Due Diligence Questionnaire (CBDDQ) The Wolfsberg Group 2020 Page 5 CBDDQ ANTI BRIBERY & CORRUPTION25 Has the ENTITY documented policies andprocedures consistent with applicable ABC regulations and requirements to [reasonably] prevent, detect and report bribery and corruption?26 Does the ENTITY have an enterprise wideprogramme that sets minimum ABC standards?27 Has the ENTITY appointed a designated officer orofficers with sufficient experience/expertise responsible for coordinating the ABC programme?28 Does the ENTITY have adequate staff withappropriate levels of experience/expertise to implement the ABC programme?

7 29Is the ENTITY 's ABC programme applicable to:30 Does the ENTITY have a global ABC policy that:30 aProhibits the giving and receiving of bribes?This includes promising, offering, giving, solicitation or receiving of anything of value, directly or indirectly, if improperly intended to influence action or obtain an advantage30 bIncludes enhanced requirements regardinginteraction with public officials?30 cIncludes a prohibition against the falsification ofbooks and records (this may be within the ABC policy or any other policy applicable to the Legal ENTITY )?31 Does the ENTITY have controls in place to monitorthe effectiveness of their ABC programme?32 Does the ENTITY 's Board or Senior ManagementCommittee receive regular Management Information on ABC matters?33 Does the ENTITY perform an Enterprise WideABC risk assessment?33 aIf Y select the frequency34 Does the ENTITY have an ABC residual risk ratingthat is the net result of the controls effectiveness and the inherent risk assessment?

8 35 Does the ENTITY 's ABC EWRA cover the inherentrisk components detailed below:35 aPotential liability created by intermediaries andother third-party providers as appropriate35 bCorruption risks associated with the countriesand industries in which the ENTITY does business, directly or through intermediaries35 cTransactions, products or services, includingthose that involve state-owned or state- controlled entities or public officials35 dCorruption risks associated with gifts andhospitality, hiring/internships, charitable donations and political contributions35 eChanges in business activities that maymaterially increase the ENTITY 's corruption risk36 Does the ENTITY 's internal audit function or otherindependent third party cover ABC Policies and Procedures?Wolfsberg Group Correspondent Banking Due Diligence Questionnaire (CBDDQ) The Wolfsberg Group 2020 Page 6 CBDDQ the ENTITY provide mandatory ABC trainingto:37 aBoard and senior Committee Management37 b1st Line of Defence37 c2nd Line of Defence37 d3rd Line of Defence37 e3rd parties to which specific complianceactivities subject to ABC risk have been outsourced37 fNon-employed workers as appropriate(contractors/consultants)38 Does the ENTITY provide ABC training that istargeted to specific roles, responsibilities and activities?

9 39 Confirm that all responses provided in the aboveSection Anti Bribery & Corruption are representative of all the LE's branches39 aIf N, clarify which questions the difference/srelate to and the branch/es that this applies bIf appropriate, provide any additional information/ context to the answers in this Group Correspondent Banking Due Diligence Questionnaire (CBDDQ) The Wolfsberg Group 2020 Page 7 CBDDQ AML, CTF & SANCTIONS POLICIES & PROCEDURES40 Has the ENTITY documented policies andprocedures consistent with applicable AML, CTF & Sanctions regulations and requirements to reasonably prevent, detect and report:40 aMoney laundering40 bTerrorist financing40 cSanctions violations41 Are the ENTITY 's policies and procedures updatedat least annually?42 Are the ENTITY 's policies and procedures gappedagainst/compared to:42 aUS Standards42 a1If Y, does the ENTITY retain a record of theresults?42 bEU Standards42 b1If Y, does the ENTITY retain a record of theresults?

10 43 Does the ENTITY have policies and proceduresthat:43 aProhibit the opening and keeping of anonymousand fictitious named accounts43 bProhibit the opening and keeping of accounts forunlicensed banks and/or NBFIs43 cProhibit dealing with other entities that providebanking services to unlicensed banks43 dProhibit accounts/relationships with shell banks43 eProhibit dealing with another ENTITY that providesservices to shell banks43 fProhibit opening and keeping of accounts forSection 311 designated entities43 gProhibit opening and keeping of accounts forany of unlicensed/unregulated remittance agents, exchanges houses, casa de cambio, bureaux de change or money transfer agents43 hAssess the risks of relationships with domesticand foreign PEPs, including their family and close associates43 iDefine escalation processes for financial crimerisk issues43 jDefine the process, where appropriate, forterminating existing customer relationships due to financial crime risk43 kSpecify how potentially suspicious activityidentified by employees is to be escalated and investigated43 lOutline the processes regarding screening forsanctions, PEPs and negative media43 mOutline the processes for the maintenance ofinternal "watchlists"44 Has the ENTITY defined a risk tolerance statementor similar document which defines a risk boundary around their business?