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{"sheet":"General","index":0,"n_rows":44,"n_cols":5,"rows_kept":44,"cut":false,"hidden":false,"merged":[[41,4,41,11],[43,4,43,11],[39,4,39,6],[16,4,16,12],[1,0,1,13],[9,0,9,13],[13,0,13,13],[14,1,14,13],[18,4,18,8],[10,0,10,13],[11,0,11,13],[12,0,12,13]]}
[]
["BRITISH VIRGIN ISLANDS FINANCIAL SERVICES COMMISSION"]
[]
[]
[]
[]
[]
[]
[]
[]
["ANTI-MONEY LAUNDERING/COUNTERING THE FINANCING OF TERRORISM (AML/CFT) RETURN"]
["Anti-money Laundering Regulations, 2008"]
["Anti-Money Laundering and Terrorist Financing Code of Practice, 2008"]
["Financial Services (Prudential and Statistical Returns) Order, 2009"]
[]
[]
[null,"Licensee Name:"]
[]
[null,"Licence Number:"]
[]
[null,"Licence Type (Tick as applicable):"]
[null,null,null,null,"Approved Investment Manager"]
[]
[null,null,null,null,"Banking Licensee"]
[]
[null,null,null,null,"Trust / Company Management Licensee"]
[]
[null,null,null,null,"Financing Business Licensee"]
[]
[null,null,null,null,"Insolvency Practitioner"]
[]
[null,null,null,null,"Insurer"]
[]
[null,null,null,null,"Insurance Manager or Intermediary"]
[]
[null,null,null,null,"Investment Business Licensee"]
[]
[null,null,null,null,"Money Services Business Licensee"]
[]
[null,"Reporting Period: "]
[]
[null,"Registered Agent: "]
[]
[null,"Registered Office Address:"]

{"sheet":"Governance","index":1,"n_rows":48,"n_cols":5,"rows_kept":48,"cut":false,"hidden":false,"merged":[[28,3,29,7],[32,3,33,7],[4,3,5,7],[10,3,11,7],[17,3,18,7],[25,3,26,7]]}
[]
[null,"1. CORPORATE GOVERNANCE"]
[null,null,"(Select applicable response to each question below from the drop boxes)"]
[null,"1.1","Board/Senior Management Oversight"]
[null,null,"1.1.1","How many Board Meetings or Senior Management Meetings has the licensee held within the last 12 months?"]
[]
[null,null,null,"(a)","Board Meetings "]
[]
[null,null,null,"(b)","Senior Management Meetings"]
[]
[null,null,"1.1.2","In the last 12 months, how many times has AML/CFT appeared as am agenda item at these meetings?"]
[]
[null,null,null,"(a)","Board Meetings "]
[]
[null,null,null,"(b)","Senior Management Meetings"]
[]
[null,1.2,"Policies and Procedures"]
[null,null,"1.2.1","How long has it been since the licensee’s AML/CFT policies and procedures were reviewed and updated?"]
[]
[null,null,null,"(a)","Policies"]
[]
[null,null,null,"(b)","Procedures"]
[]
[null,null,"1.2.2","Was the review conducted internally or by a third party?"]
[]
[null,null,"1.2.3","How often does the licensee prepare a report on the operations and effectiveness of its AML/CFT systems and controls?"]
[]
[]
[null,null,"1.2.4","Is the report prepared on the operations and effectiveness of the licensee’s AML/CFT systems and controls presented to the Board?"]
[]
[]
[null,1.3,"Institutional Risk Assessment"]
[null,null,"1.3.1","How long has it been since the licensee performed an assessment of the ML/TF risks for all of its business lines?"]
[]
[]
[null,null,"1.3.2","Did the Board approve the risk assessment?"]
[]
[null,null,"1.3.3","Based on the risk assessment, what was the risk rating applied to each of the following?"]
[]
[null,null,null,"(a)","Products/Services"]
[]
[null,null,null,"(b)","Customers"]
[]
[null,null,null,"(c) ","Geography"]
[]
[null,null,null,"(d)","Distribution channels"]
[]
[null,null,null,"(e) ","Overall licensee rating"]

{"sheet":"Record Keeping","index":2,"n_rows":26,"n_cols":5,"rows_kept":26,"cut":false,"hidden":false,"merged":[[0,7,0,9],[4,2,5,7],[9,4,9,5],[15,4,15,5],[7,2,7,9]]}
[]
[null,"2. RECORD KEEPING"]
[null,null,"(Select applicable response to each question below from the drop boxes or check boxes)"]
[]
[null,"2.1","Does the licensee have policies and procedures in place regarding the records that must be retained, including retention periods, in accordance with the AMLTFCOP? "]
[]
[]
[null,"2.2","What channels does the licensee use to make these policies and procedures readily accessible by staff?  "]
[]
[null,null,null,null,"Electronic Copies"]
[]
[null,null,null,null,"Hard Copies"]
[]
[null,null,null,null,"Intranet Site"]
[]
[null,null,null,null,"Requests to Supervisors/Managers"]
[]
[null,"2.3","Are staff aware of the licensee’s policies and procedures for record retention?"]
[]
[null,"2.4","Are the licensee’s records maintained in the Virgin Islands?"]
[]
[null,"2.5","Do the records maintained by the licensee include transaction records?"]
[]
[null,"2.6","Are the licensee’s records held in a readily retrievable format?"]
[]
[null,"2.7","In what format are the licensee’s records held?"]

{"sheet":"Risk Profile","index":3,"n_rows":83,"n_cols":5,"rows_kept":83,"cut":false,"hidden":false,"merged":[[52,3,53,7],[55,3,56,7],[68,3,69,7],[71,3,72,7],[82,3,83,7],[49,3,50,7],[11,3,12,7],[46,3,47,7],[23,3,24,7],[31,3,32,7],[39,3,40,7],[20,3,20,8],[42,3,44,7]]}
[]
[null,"3. RISK PROFILE"]
[null,"(Select applicable response to each question below from the drop boxes)"]
[]
[null,"3.1","Products and Services"]
[null,null,"3.1.1","Approximately how many products and services are offered by the licensee?"]
[]
[null,null,null,"(a)","Products (Total No.) "]
[]
[null,null,null,"(b)","Services (Total No.)"]
[]
[null,null,"3.1.2","What percentage of the licensee’s products and services fall into the following risk categories, as defined in the licensee’s ML/TF risk assessment?"]
[]
[null,null,null,"(a)","High "]
[]
[null,null,null,"(b)","Medium"]
[]
[null,null,null,"(c) ","Low"]
[]
[null,3.2,"Distribution Channels"]
[null,null,"3.2.1","What percentage of the licensee's business relationships are conducted face-to-face?"]
[]
[null,3.3,"Customer Exposure"]
[null,null,"3.3.1","What percentage of the licensee's customers fall into the following risk ML/TF risk categories?"]
[]
[null,null,null,"(a)","High "]
[]
[null,null,null,"(b)","Medium"]
[]
[null,null,null,"(c) ","Low"]
[]
[null,null,"3.3.2","What percentage of the licensee’s customers fall into each of the following customer types?"]
[]
[null,null,null,"(a)","Retail"]
[]
[null,null,null,"(b)","Institutional"]
[]
[null,null,null,"(c) ","Professional"]
[]
[null,null,"3.3.3","What percentage of the licensee’s business has been established prior to verification procedures being completed?"]
[]
[]
[null,null,"3.3.4","Where the licensee has established a business relationship with incomplete customer verification, the licensee implements specific risk management procedures with respect to that relationship:"]
[]
[]
[]
[null,null,"3.3.5","What percentage of business relationships have been rejected or terminated by the licensee due to concerns about CDD within the last 12 months?"]
[]
[]
[null,null,"3.3.6","What percentage of transactions have been rejected or terminated by the licensee due to concerns about CDD within the last 12 months?"]
[]
[]
[null,null,"3.3.7","What percentage of business relationships have been rejected or terminated by the licensee due to incomplete CDD information within the last 12 months?"]
[]
[]
[null,null,"3.3.8","What percentage of transactions have been rejected or terminated by the licensee due to incomplete CDD information within the last 12 months?"]
[]
[]
[]
[null,"3.4","PEPs"]
[null,null,"3.4.1","Does the licensee conduct screening to identify whether customers are PEPs?"]
[]
[null,null,"3.4.2","Is this PEP screening initiated automatically or manually? "]
[]
[null,null,"3.4.3","How frequently is enhanced monitoring of persons identified as PEPs conducted?"]
[]
[null,null,"3.4.4","Of the licensee’s existing customer base, how many are PEPs?"]
[]
[null,null,"3.4.5","What percentage of customers identified as PEPs have NOT been approved by senior management for onboarding/continuation of a relationship?"]
[]
[]
[null,null,"3.4.6","What percentage of customers previously classified as PEP have been declassified as PEPs within the last 12 months?"]
[]
[]
[]
[null,"3.5","Targeted Financial Sanctions"]
[null,null,"3.5.1","Does the licensee screen customers against UN and other sanctions lists?"]
[]
[null,null,"3.5.2","Is sanctions screening conducted automatically or manually?"]
[]
[null,null,"3.5.3","How frequently is sanctions screening conducted?"]
[]
[null,null,"3.5.4","Does the licensee’s screening measures include a screening of its entire customer base immediately after new persons are added to sanctions lists?"]

{"sheet":"Risk Monitoring","index":4,"n_rows":65,"n_cols":4,"rows_kept":65,"cut":false,"hidden":false,"merged":[[56,3,58,7],[60,3,62,7],[64,3,65,7],[6,3,7,7],[9,3,10,7],[12,3,13,7],[15,3,16,7],[20,3,21,7],[27,3,28,7],[36,3,37,7],[41,3,42,7],[48,3,49,7],[53,3,54,7]]}
[]
[null,"4. RISK MONITORING"]
[null,"(Select applicable response to each question below from the drop boxes)"]
[]
[null,"4.1","Policies and Procedures"]
[]
[null,null,"4.1.1","Has the licensee implemented policies and procedures reflecting a risk-based approach to ongoing client monitoring aligned to the ML/TF risks presented by its business?"]
[]
[]
[null,null,"4.1.2","Has the licensee implemented policies and procedures for updating CDD information on existing customers as required by the AMLTFCOP? "]
[]
[]
[null,null,"4.1.3","Has the licensee implemented policies and procedures for carrying out ECDD on high risk customers as required by the AMLTFCOP? "]
[]
[]
[null,null,"4.1.4","Has the licensee implemented policies and procedures to identify complex or unusually large transactions with no visible economic or lawful purpose?"]
[]
[]
[null,4.2,"AML/CFT Audit Function"]
[]
[null,null,"4.2.1","Does the licensee maintain an independent audit function, adequately resourced to test compliance with AML/CFT requirements?"]
[]
[]
[null,null,"4.2.2","Does the audit function include sample testing of client files?"]
[]
[null,4.3,"Third Party Reliance"]
[]
[null,null,"4.3.1","Does the licensee place reliance on third parties for the introduction of an applicant for business as defined in the AMLTFCOP? "]
[]
[]
[null,null,"4.3.2","Are third parties within the same group structure relied on?"]
[]
[null,null,"4.3.3","How many third party agreements does the licensee currently have in place?"]
[]
[null,null,"4.3.4","What percentage of the third party agreements in place are group related?"]
[]
[null,null,"4.3.5","What percentage of existing third party agreements has the licensee assessed to ensure full compliance with AML legislation?"]
[]
[]
[null,null,"4.3.6","What percentage of the licensee’s business has been introduced by a third party?"]
[]
[null,null,"4.3.7","Does the licensee have a programme in place for the regular testing and verification of AML/CFT documentation sourced through third parties to ensure:"]
[]
[]
[null,null,"i)","AML/CFT procedures applied by third parties reflect those of the licensee"]
[]
[null,null,"ii)","AML/CFT information can be retrieved without delay"]
[]
[null,null,"iii)","The quality of documents held by the third party are sufficient to ensure completeness of records in accordance with the AMLTFCOP "]
[]
[]
[null,null,"4.3.8","What is the frequency of testing of the third party arrangements currently in place?"]
[]
[null,null,"4.3.9","Are records evidencing the testing of third party arrangements maintained by the licensee?"]
[]
[]
[null,null,"4.3.10","What percentage of the licensee’s business relationships or transactions established through third party relationships have been rejected or terminated by the licensee due to concerns about CDD within the last 12 months?"]
[]
[]
[]
[null,null,"4.3.11","What percentage of the licensee’s business relationships or transactions established through third party relationships, have been rejected or terminated by the licensee due to incomplete CDD information within the last 12 months?"]
[]
[]
[]
[null,null,"4.3.12","What percentage of the licensee’s third party agreements has the licensee terminated within the last 12 months?"]

{"sheet":"Geographic Exposure","index":5,"n_rows":265,"n_cols":7,"rows_kept":265,"cut":false,"hidden":false,"merged":[[10,2,11,2],[264,2,264,3],[10,5,11,5],[10,3,11,3],[10,4,11,4]]}
[]
[null,"5. GEOGRAPHIC EXPOSURE"]
[]
[null,5.0999999999999996,"Insert the following in the table below: "]
[null,null,"(a) the number of customers identified as PEPs from each jurisdiction listed",null,null,null,"*"]
[]
[null,null,"(b) the number of third party introducers from each jurisdiction listed",null,null,null,"*"]
[]
[null,"*Select N/A in the applicable drop boxes above where the licensee does not have PEP customers or third-party introducer arrangements. "]
[]
[null,null,"Jurisdiction","Country Code","PEP Customers Per Jurisdiction","Third Party Introducers Per Jurisdiction"]
[]
[null,null,"Afghanistan","AFG",0,0]
[null,null,"Åland Islands","ALA",0,0]
[null,null,"Albania","ALB",0,0]
[null,null,"Algeria","DZA",0,0]
[null,null,"American Samoa","ASM",0,0]
[null,null,"Andorra","AND",0,0]
[null,null,"Angola","AGO",0,0]
[null,null,"Anguilla","AIA",0,0]
[null,null,"Antarctica","ATA",0,0]
[null,null,"Antigua and Barbuda","ATG",0,0]
[null,null,"Argentina","ARG",0,0]
[null,null,"Armenia","ARM",0,0]
[null,null,"Aruba","ABW",0,0]
[null,null,"Australia","AUS",0,0]
[null,null,"Austria","AUT",0,0]
[null,null,"Azerbaijan","AZE",0,0]
[null,null,"Bahamas (the)","BHS",0,0]
[null,null,"Bahrain","BHR",0,0]
[null,null,"Bangladesh","BGD",0,0]
[null,null,"Barbados","BRB",0,0]
[null,null,"Belarus","BLR",0,0]
[null,null,"Belgium","BEL",0,0]
[null,null,"Belize","BLZ",0,0]
[null,null,"Benin","BEN",0,0]
[null,null,"Bermuda","BMU",0,0]
[null,null,"Bhutan","BTN",0,0]
[null,null,"Bolivia (Plurinational State of)","BOL",0,0]
[null,null,"Bonaire, Sint Eustatius and Saba","BES",0,0]
[null,null,"Bosnia and Herzegovina","BIH",0,0]
[null,null,"Botswana","BWA",0,0]
[null,null,"Bouvet Island","BVT",0,0]
[null,null,"Brazil","BRA",0,0]
[null,null,"British Indian Ocean Territory (the)","IOT",0,0]
[null,null,"Brunei Darussalam","BRN",0,0]
[null,null,"Bulgaria","BGR",0,0]
[null,null,"Burkina Faso","BFA",0,0]
[null,null,"Burundi","BDI",0,0]
[null,null,"Cabo Verde","CPV",0,0]
[null,null,"Cambodia","KHM",0,0]
[null,null,"Cameroon","CMR",0,0]
[null,null,"Canada","CAN",0,0]
[null,null,"Cayman Islands (the)","CYM",0,0]
[null,null,"Central African Republic (the)","CAF",0,0]
[null,null,"Chad","TCD",0,0]
[null,null,"Chile","CHL",0,0]
[null,null,"China","CHN",0,0]
[null,null,"Christmas Island","CXR",0,0]
[null,null,"Cocos (Keeling) Islands (the)","CCK",0,0]
[null,null,"Colombia","COL",0,0]
[null,null,"Comoros (the)","COM",0,0]
[null,null,"Congo (the Democratic Republic of the)","COD",0,0]
[null,null,"Congo (the)","COG",0,0]
[null,null,"Cook Islands (the)","COK",0,0]
[null,null,"Costa Rica","CRI",0,0]
[null,null,"Côte d'Ivoire","CIV",0,0]
[null,null,"Croatia","HRV",0,0]
[null,null,"Cuba","CUB",0,0]
[null,null,"Curaçao","CUW",0,0]
[null,null,"Cyprus","CYP",0,0]
[null,null,"Czech Republic","CZE",0,0]
[null,null,"Denmark","DNK",0,0]
[null,null,"Djibouti","DJI",0,0]
[null,null,"Dominica","DMA",0,0]
[null,null,"Dominican Republic (the)","DOM",0,0]
[null,null,"Ecuador","ECU",0,0]
[null,null,"Egypt","EGY",0,0]
[null,null,"El Salvador","SLV",0,0]
[null,null,"Equatorial Guinea","GNQ",0,0]
[null,null,"Eritrea","ERI",0,0]
[null,null,"Estonia","EST",0,0]
[null,null,"Ethiopia","ETH",0,0]
[null,null,"Falkland Islands (the) [Malvinas]","FLK",0,0]
[null,null,"Faroe Islands (the)","FRO",0,0]
[null,null,"Fiji","FJI",0,0]
[null,null,"Finland","FIN",0,0]
[null,null,"France","FRA",0,0]
[null,null,"French Guiana","GUF",0,0]
[null,null,"French Polynesia","PYF",0,0]
[null,null,"French Southern Territories (the)","ATF",0,0]
[null,null,"Gabon","GAB",0,0]
[null,null,"Gambia (the)","GMB",0,0]
[null,null,"Georgia","GEO",0,0]
[null,null,"Germany","DEU",0,0]
[null,null,"Ghana","GHA",0,0]
[null,null,"Gibraltar","GIB",0,0]
[null,null,"Greece","GRC",0,0]
[null,null,"Greenland","GRL",0,0]
[null,null,"Grenada","GRD",0,0]
[null,null,"Guadeloupe","GLP",0,0]
[null,null,"Guam","GUM",0,0]
[null,null,"Guatemala","GTM",0,0]
[null,null,"Guernsey","GGY",0,0]
[null,null,"Guinea","GIN",0,0]
[null,null,"Guinea-Bissau","GNB",0,0]
[null,null,"Guyana","GUY",0,0]
[null,null,"Haiti","HTI",0,0]
[null,null,"Heard Island and McDonald Islands","HMD",0,0]
[null,null,"Honduras","HND",0,0]
[null,null,"Hong Kong","HKG",0,0]
[null,null,"Hungary","HUN",0,0]
[null,null,"Iceland","ISL",0,0]
[null,null,"India","IND",0,0]
[null,null,"Indonesia","IDN",0,0]
[null,null,"Iran (Islamic Republic of)","IRN",0,0]
[null,null,"Iraq","IRQ",0,0]
[null,null,"Ireland","IRL",0,0]
[null,null,"Isle of Man","IMN",0,0]
[null,null,"Israel","ISR",0,0]
[null,null,"Italy","ITA",0,0]
[null,null,"Jamaica","JAM",0,0]
[null,null,"Japan","JPN",0,0]
[null,null,"Jersey","JEY",0,0]
[null,null,"Jordan","JOR",0,0]
[null,null,"Kazakhstan","KAZ",0,0]
[null,null,"Kenya","KEN",0,0]
[null,null,"Kiribati","KIR",0,0]
[null,null,"Korea (the Democratic People's Republic of)","PRK",0,0]
[null,null,"Korea (the Republic of)","KOR",0,0]
[null,null,"Kosovo (the Republic of)","XKX",0,0]
[null,null,"Kuwait","KWT",0,0]
[null,null,"Kyrgyzstan","KGZ",0,0]
[null,null,"Lao People's Democratic Republic (the)","LAO",0,0]
[null,null,"Latvia","LVA",0,0]
[null,null,"Lebanon","LBN",0,0]
[null,null,"Lesotho","LSO",0,0]
[null,null,"Liberia","LBR",0,0]
[null,null,"Libya","LBY",0,0]
[null,null,"Liechtenstein","LIE",0,0]
[null,null,"Lithuania","LTU",0,0]
[null,null,"Luxembourg","LUX",0,0]
[null,null,"Macao","MAC",0,0]
[null,null,"Macedonia (the former Yugoslav Republic of)","MKD",0,0]
[null,null,"Madagascar","MDG",0,0]
[null,null,"Malawi","MWI",0,0]
[null,null,"Malaysia","MYS",0,0]
[null,null,"Maldives","MDV",0,0]
[null,null,"Mali","MLI",0,0]
[null,null,"Malta","MLT",0,0]
[null,null,"Marshall Islands (the)","MHL",0,0]
[null,null,"Martinique","MTQ",0,0]
[null,null,"Mauritania","MRT",0,0]
[null,null,"Mauritius","MUS",0,0]
[null,null,"Mayotte","MYT",0,0]
[null,null,"Mexico","MEX",0,0]
[null,null,"Micronesia (Federated States of)","FSM",0,0]
[null,null,"Moldova (the Republic of)","MDA",0,0]
[null,null,"Monaco","MCO",0,0]
[null,null,"Mongolia","MNG",0,0]
[null,null,"Montenegro","MNE",0,0]
[null,null,"Montserrat","MSR",0,0]
[null,null,"Morocco","MAR",0,0]
[null,null,"Mozambique","MOZ",0,0]
[null,null,"Myanmar","MMR",0,0]
[null,null,"Namibia","NAM",0,0]
[null,null,"Nauru","NRU",0,0]
[null,null,"Nepal","NPL",0,0]
[null,null,"Netherlands (the)","NLD",0,0]
[null,null,"New Caledonia","NCL",0,0]
[null,null,"New Zealand","NZL",0,0]
[null,null,"Nicaragua","NIC",0,0]
[null,null,"Niger (the)","NER",0,0]
[null,null,"Nigeria","NGA",0,0]
[null,null,"Niue","NIU",0,0]
[null,null,"Norfolk Island","NFK",0,0]
[null,null,"Northern Mariana Islands (the)","MNP",0,0]
[null,null,"Norway","NOR",0,0]
[null,null,"Oman","OMN",0,0]
[null,null,"Pakistan","PAK",0,0]
[null,null,"Palau","PLW",0,0]
[null,null,"Palestine, State of","PSE",0,0]
[null,null,"Panama","PAN",0,0]
[null,null,"Papua New Guinea","PNG",0,0]
[null,null,"Paraguay","PRY",0,0]
[null,null,"Peru","PER",0,0]
[null,null,"Philippines (the)","PHL",0,0]
[null,null,"Pitcairn Islands","PCN",0,0]
[null,null,"Poland","POL",0,0]
[null,null,"Portugal","PRT",0,0]
[null,null,"Puerto Rico","PRI",0,0]
[null,null,"Qatar","QAT",0,0]
[null,null,"Réunion","REU",0,0]
[null,null,"Romania","ROU",0,0]
[null,null,"Russian Federation (the)","RUS",0,0]
[null,null,"Rwanda","RWA",0,0]
[null,null,"Saint Barthélemy","BLM",0,0]
[null,null,"Saint Helena, Ascension and Tristan da Cunha","SHN",0,0]
[null,null,"Saint Kitts and Nevis","KNA",0,0]
[null,null,"Saint Lucia","LCA",0,0]
[null,null,"Saint Martin (French part)","MAF",0,0]
[null,null,"Saint Pierre and Miquelon","SPM",0,0]
[null,null,"Saint Vincent and the Grenadines","VCT",0,0]
[null,null,"Samoa","WSM",0,0]
[null,null,"San Marino","SMR",0,0]
[null,null,"Sao Tome and Principe","STP",0,0]
[null,null,"Saudi Arabia","SAU",0,0]
[null,null,"Senegal","SEN",0,0]
[null,null,"Serbia","SRB",0,0]
[null,null,"Seychelles","SYC",0,0]
[null,null,"Sierra Leone","SLE",0,0]
[null,null,"Singapore","SGP",0,0]
[null,null,"Sint Maarten (Dutch part)","SXM",0,0]
[null,null,"Slovakia","SVK",0,0]
[null,null,"Slovenia","SVN",0,0]
[null,null,"Solomon Islands","SLB",0,0]
[null,null,"Somalia","SOM",0,0]
[null,null,"South Africa","ZAF",0,0]
[null,null,"South Georgia and the South Sandwich Islands","SGS",0,0]
[null,null,"South Sudan","SSD",0,0]
[null,null,"Spain","ESP",0,0]
[null,null,"Sri Lanka","LKA",0,0]
[null,null,"Sudan (the)","SDN",0,0]
[null,null,"Suriname","SUR",0,0]
[null,null,"Svalbard and Jan Mayen","SJM",0,0]
[null,null,"Swaziland","SWZ",0,0]
[null,null,"Sweden","SWE",0,0]
[null,null,"Switzerland","CHE",0,0]
[null,null,"Syrian Arab Republic","SYR",0,0]
[null,null,"Taiwan (Province of China)","TWN",0,0]
[null,null,"Tajikistan","TJK",0,0]
[null,null,"Tanzania, United Republic of","TZA",0,0]
[null,null,"Thailand","THA",0,0]
[null,null,"Timor-Leste","TLS",0,0]
[null,null,"Togo","TGO",0,0]
[null,null,"Tokelau","TKL",0,0]
[null,null,"Tonga","TON",0,0]
[null,null,"Trinidad and Tobago","TTO",0,0]
[null,null,"Tunisia","TUN",0,0]
[null,null,"Turkey","TUR",0,0]
[null,null,"Turkmenistan","TKM",0,0]
[null,null,"Turks and Caicos Islands (the)","TCA",0,0]
[null,null,"Tuvalu","TUV",0,0]
[null,null,"Uganda","UGA",0,0]
[null,null,"Ukraine","UKR",0,0]
[null,null,"United Arab Emirates (the)","ARE",0,0]
[null,null,"United Kingdom of Great Britain and Northern Ireland (the)","GBR",0,0]
[null,null,"United States Minor Outlying Islands (the)","UMI",0,0]
[null,null,"United States of America (the)","USA",0,0]
[null,null,"Uruguay","URY",0,0]
[null,null,"Uzbekistan","UZB",0,0]
[null,null,"Vanuatu","VUT",0,0]
[null,null,"Vatican City State (Holy See)","VAT",0,0]
[null,null,"Venezuela (Bolivarian Republic of)","VEN",0,0]
[null,null,"Vietnam","VNM",0,0]
[null,null,"Virgin Islands (British)","VGB",0,0]
[null,null,"Virgin Islands (U.S.)","VIR",0,0]
[null,null,"Wallis and Futuna","WLF",0,0]
[null,null,"Western Sahara","ESH",0,0]
[null,null,"Yemen","YEM",0,0]
[null,null,"Zambia","ZMB",0,0]
[null,null,"Zimbabwe","ZWE",0,0]
[null,null,"Other",null,0,0]
[null,null,"Unknown",null,0,0]
[null,null,"TOTAL",null,{"$f":"SUM(E13:E264)","v":0},{"$f":"SUM(F13:F264)","v":0}]

{"sheet":"SARs","index":6,"n_rows":19,"n_cols":8,"rows_kept":19,"cut":false,"hidden":false,"merged":[[24,3,24,6],[15,3,16,6],[18,3,19,6],[4,3,5,6],[7,3,8,6],[10,3,11,6]]}
[]
[null,"6.","SUSPICIOUS ACTIVITY REPORTING"]
[null,null,"(Insert responses or select applicable responses from the drop boxes as required)"]
[]
[null,null,6.1,"How many suspicious activities/transactions were reported to the MLRO in the last 12 months?"]
[]
[]
[null,null,6.2,"How many of the suspicious activities/transactions reported to the MLRO in the last 12 months resulted in a SAR being filed with the FIA? "]
[]
[]
[null,null,6.3,"Where suspicious activities/transactions did not result in the filing of a SAR with the FIA, was the reason for such decision taken documented in each instance?"]
[]
[]
[null,null,6.4,"What is the value of the associated transactions of the SARs reported to the FIA?",null,null,null,"USD"]
[]
[null,null,6.5,"What is the average time taken from the date of transaction to the time a suspicious activity is reported to the MLRO?"]
[]
[]
[null,null,6.6,"What is the average number of days taken by the MLRO to analyse a suspicious transaction before filing an SAR with the FIA?"]

{"sheet":"Other Issues","index":7,"n_rows":6,"n_cols":9,"rows_kept":6,"cut":false,"hidden":false,"merged":[[3,3,3,7],[6,3,23,8]]}
[]
[null,"7.","OTHER ISSUES"]
[null,null,null,null,null,null,null,null,"Select (Yes or No)"]
[null,null,7.1,"Are there any other AML/CFT issues to which you wish to draw to the Commission's attention?"]
[]
[null,null,"7.1.1","If the response to 7.1 is yes, provide details below:"]

{"sheet":"Declaration","index":8,"n_rows":20,"n_cols":12,"rows_kept":20,"cut":false,"hidden":false,"merged":[[3,2,3,13],[4,3,4,13],[6,3,6,6],[6,8,6,12],[15,3,15,6],[15,8,15,12],[12,10,12,12]]}
[]
[null,"8. DECLARATION"]
[]
[null,null,"DECLARATION"]
[null,null,null,"I am authorised to complete this declaration on behalf of the licensee. I certify that this return represents an accurate and fair view of the licensee's position at the above reporting period. I undertake that if there are other material facts affecting the licensee's affairs which, in my judgement should be disclosed, I will advise the Financial Services Commission.   I understand that the Commission may take enforcement action against the licensee under the Financial Services Commission Act where false, inaccurate or misleading information is submitted within this return."]
[]
[]
[null,null,null,"Name (Last Name, First Name)",null,null,null,null,"Name of Organisation (if not within Licensee)"]
[]
[null,null,null,"Relationship to Licensee: "]
[null,null,null,"       Registered Agent",null,"Authorised Representative ",null,null,"Insurance Manager",null,null,"Legal Representative "]
[]
[null,null,null,"       Director/Senior Officer",null,"Employee",null,null,"Other (please specify):"]
[]
[]
[]
[null,null,null,"Email Address",null,null,null,null,"Telephone Number"]
[]
[]
[null,null,null,"Date"]

{"sheet":"Answer Key","index":9,"n_rows":55,"n_cols":4,"rows_kept":55,"cut":false,"hidden":true,"merged":[[1,0,2,0]]}
[]
["Answer Key for Questions","Yes","Yes ","Annually"]
[null,"No","No","Every 2 years"]
[null,null,"N/A","Every 3 years"]
[null,0,null,"Event Triggered "]
[null,"1 to 4 ","less than 1%","N/A"]
[null,"5 to 8 ","1 to 5% "]
[null,"9 to 12 ","5 to 10%"]
[null,"more than 12","more than 10%"]
[null,null,"N/A"]
[]
[null,"less than 6 months",null,"less than 1 day "]
[null,"6 to 12 months","Automated ","1 to 2 days"]
[null,"12 to 18 months ","Manual","3 to 5 days"]
[null,"more than 18 months","Both ","more than 5 days"]
[null,null,"N/A","N/A"]
[]
[null,"1 to 4 months"]
[null,"5 to 8 months ","Daily","Internal "]
[null,"9 to 12 months","Weekly","Third Party "]
[null,"more than 12 months","Monthly","N/A"]
[null,"Never","Quarterly "]
[null,null,"Bi-annually"]
[null,null,"Annually"]
[null,"Low","Ad-hoc","Electronic Copies"]
[null,"Medium ",null,"Hard Copies"]
[null,"High",null,"Intranet Site"]
[null,"N/A","N/A","Requests to Supervisors/Managers"]
[null,null,"1 to 25"]
[null,"0 to 5","26 to 50"]
[null,"6 to 15","51 to 75","Paper "]
[null,"16 to 25","75 to 100","Digital"]
[null,"over 25","more than 100","Combination: Paper & Digital"]
[]
[]
[null,"less than 25%","N/A"]
[null,"25 to 50%",0]
[null,"50 to 75 %","less than 25%"]
[null,"more than 75%","25 to 50%","N/A"]
[null,"N/A","50 to 75%",0]
[null,null,"more than 75%","less than 25%"]
[null,null,null,"25 to 50%"]
[null,null,null,"50 to 75% "]
[null,null,null,"75 to 99%"]
[null,"Annually",null,1]
[null,"Bi-Annually"]
[null,"Every 2 years"]
[null,"More than 2 years"]
[null,"Never","Always"]
[null,null,"75% to 90% of the time"]
[null,null,"50% to 75% of the time"]
[null,null,"25% to 50% of the time"]
[null,null,"less than 25% of the time"]
[null,null,"Never"]
[null,null,"N/A"]