BANK OF INDIA. HEAD OFFICE, MUMBAIKNOW YOUR CUSTOMER AND ANTI-MONEY LAUNDERING

WOLFSBERG GROUP QUESTIONNAIRE

Sr. Questionnaire ResponseNo.1. Website Address: www.bankofindia.co.in

2. Name of the Local Licensing Authority/Banking Reserve Bank of IndiaRegulator

3. Head Office Address Star House, C-5, G-Block,Bandra Kurla Complex,Bandra East,Mumbai-40005, India

4. Head Office Website Address www.bankofindia.co.in

5. Name of Head Office Licensing Reserve Bank of IndiaAuthority/Banking Regulator

SECTION - II - WOLFSBERG QUESTIONNAIRE

GENERAL AML POLICIES, PRACTICES AND PROCEDURES

Sr.No. Questionnaire Response1. Is the AML Compliance program approved by YES NO

the Fl's Board or a Senior Committee?2. Does the FI have a legal and regulatory YES NO

compliance program that includes adesignated officer that is responsible for co-ordinating and overseeing the AML framework

3. Has the FI formulated written policies YES NOdocumenting the processes that they have inplace to prevent, detect and report suspicioustransactions?

4. In addition to inspections by the Government YES NOsupervisors/regulators, does the FI client havean internal audit function or other independentthird party who assesses AML policies andpractices on a regular basis?

5. Does the FI have a policy- prohibiting YES NOaccounts/relationships with Shell Banks? (AShell Bank is defined as a Bank incorporatedin a jurisdiction in which it has no physicalpresence and which is unaffiliated with aregulated financial group)

6. Does the FI have policies to reasonably YES NOensure that they will not conduct transactionswith or on behalf of Shell Banks through anyof its accounts or products?

~~~ ~~7.Does- the FI have policies covering YES NOrelationships with politically exposed persons

l4rr ~ .A.-' (PEP's), their family and close associates?I*c&.tl~~_,I. Does the FI have record retention procedures YES NO

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BANK OF INDIA. HEAD OFFICE. MUMBAISr.No. Questionnaire Response

that comply with applicable law?9. Are the FI's AML Policies and practices being YES NO

applied to all branches and subsidiaries of theFI both in the home country and in locationsoutside of that jurisdiction?

RISK ASSESSMENT

Sr.No. Questionnaire Response10. Does the FI have a risk-based assessment of YES NO

its customer base and their transactions?11. Does the FI determine the appropriate level of YES NO

enhanced due diligence necessary for thosecategories of customers and transactions thatthe FI has reason to believe pose a heightenedrisk of illicit activities at or through the FI?

12. Has the FI implemented processes for the YES NOidentification of those customers who maintainor operate accounts or conduct transactions?

13. Does the FI have a requirement to collect YES NOinformation regarding its customers' businessactivities?

14. Does the FI, assess its FI customers' AML YES NOPolicies or practices?

15. Does the FI have a process to review and YES NOwhere appropriate, update customerinformation relating to high risk clientinformation?

16. Does the FI have procedures to establish a YES NOrecord for each new customer noting theirrespective identification documents and 'KnowYour Customer' information?

17. Does the FI complete a risk-based assessment YES NOto understand the normal and expectedtransactions of its customers?

18. Does the FI have policies or practices for the YES NOidentification and reporting of transactions thatare required to be reported to the authorities?

19. Where cash transaction reporting is mandatory, YES NODoes the FI have procedures to identifytransactions structured to avoid suchobligations?

20. Does the FI screen customers and transactions YES NOagainst lists of persons, entities or countriesissued by Government/competent authorities?

21. Does the FI have policies to reasonably ensure YES NO- that it only operates with correspondent Banks.g.~ ~~~ that possess licenses to operate in their~~ il countries of origin?

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BANK OF INDIA. HEAD OFFICE. MUMBAI

TRANSACTION MONITORING

Sr.No. Questionnaire Response22. Does the FI have a monitoring program for YES NG

unusual and potentially suspicious activity thatcovers funds transfers and monetaryinstruments such as travellers checks, moneyorders, etc.

23. Does the FI provide AML Training to relevant YES NGemployees that includes:• Identification and reporting of transactions

that must be reported to Governmentauthorities.

• Examples of different forms of MoneyLaundering involving the Fl's products andservices.

• Internal policies to prevent MoneyLaunderinq

Sr.No. Questionnaire Response24. Does the FI retain records of its training YES NG

sessions including attendance records andrelevant training materials used?

25. Does the FI communicate new AML related YES NGlaws or changes to existing AML relatedpolicies or practices to relevant employees?

26. Does the FI employ third parties to carry out ¥ES NOsome of the functions of the FI?

27. If the answer to question 26 is Yes. YES NODoes the FI provide AML training to relevantthird parties that includes:• Identification and reporting of transactionsthat must be reported to Governmentauthorities.

• Examples of difference forms of MoneyLaundering involving the FI's products andservices.

• Internal policies to prevent MoneyLaundering.

BANK OF INDIA, HEAD OFFICE, MUMBAI

SECTION -111- SUPPLEMENTARY QUESTIONS

ResponseQuestionnaireSr.No.YES NODoes the FI have any anonymous or

numbered Accounts?28.

Does the FI maintain nested accounts (i.e. doyou allow your customers/other financialinstitutions direct access to your accountsheld with us)? If yes, please provide YES/NOAnswers to Questions (A) to (C). (YES/NO)

¥liS NO29.

NOA) Do you verify the identity of such Bankcustomers and conduct additional duediligence on them?

YES

NOB) Please confirm you conduct ongoingmonitoring on these customers.

YES

C) Do you identify the owners of the Banksthat maintain nested accounts. If its sharesnot publicly traded?

YES NO

NODoes the FI maintain correspondent Bankingrelationships with another FI who allows directuse of their correspondent account by thirdparties to transact business on their behalf(i.e. payable through account or nestedaccount)?

30.

NODoes the FI by the following definition hold anoffshore banking License? (License toconduct banking activities which as acondition of the license, prohibits the licensedentity from conducting banking activities withthe citizens of, or in the local currency of, thecountry which issued the license).

31.

Does the FI have specific systems andcontrols in place to screen transactions forcustomers or transactions deemed to be ofsignificant high risk (which may includepersons, entities or countries) against listsissued by Government/Internationalbodies/competent authorities, which include(please provide YES/NO Answer to eachquestion (A) to(E) below): •A)UKB) EUC)USD)UNE) Other Local Regulation

32.

A) YESB) YESC) YESD) YESE) YES

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BANK OF INDIA. HEAD OFFICE. MUMBAI

Space for additional information:Please indicate which question the information is referring to.)

Name Shri Subhash C Arora

Title Chief Compliance Officer & General Manager

Signature ~

Date 01.04.2013