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Under Regulation 31 of the Financial Intelligence and Anti-Money Laundering Regulations (FIAMLR) 2018, a reporting person (LS Advisors Ltd) shall establish and maintain appropriate procedures for monitoring and testing compliance with the Anti-Money Laundering or Combatting the Financing of Terrorism (AML/CFT) requirements, having regard to ensuring that LS Advisors Ltd has robust and documented arrangements for managing the risks and prompt action is taken to remedy any deficiencies in arrangements.
This Compliance Questionnaire serves as testing to LS Advisors Ltd (LSA) to meet and fulfil its above legal obligations. This Compliance Questionnaire should be duly completed and signed by ALL staff concerned at LS Advisors Ltd.
Please complete and answer ALL questions below. NO Questions should be left unanswered. Further information should be provided where applicable.
All information provided in this Compliance Questionnaire will be strictly kept confidential. LS Advisors Ltd has a legal duty to record and maintain data in accordance with Data Protection Act and relevant Data Protection Regulations.
IMPORTANT NOTES:
Answers to the questions should be provided in good faith. Any false or any misleading information provided in this Compliance Questionnaire will be considered as a serious misconduct and the staff concerned will be subjected to sanctions and/or disciplinary actions, up to and including immediate termination of the employment agreement.
You are not authorised to share or discuss with your fellow colleagues, and you should not be under the influence of anyone at LS Advisors Ltd for any answers you provide in this Compliance Questionnaire. For any doubts or clarifications regarding any questions, you should directly contact the Head of Compliance of LS Advisors Ltd.
You are required to submit the Compliance Questionnaire by .................. (17:00). Any late submission after the prescribed deadline will not be considered and your case will be referred to the Board of Directors of LS Advisors Ltd for further disciplinary action.

1. Have you been provided a soft copy of LS Advisors Ltd (LSA)’s Internal Control Manual 2024 (Version 5) along with its policies and procedures as per relevant appendices?

1. Have you been provided a soft copy of LS Advisors Ltd (LSA)’s Internal Control Manual 2024 (Version 5) along with its policies and procedures as per relevant appendices?
A
B

2. Have you been provided training on LSA’s Internal Control Manual (Version 5) along with its policies and procedures as per relevant appendices?

2. Have you been provided training on LSA’s Internal Control Manual (Version 5) along with its policies and procedures as per relevant appendices?
A
B

3. Do you know how to access LSA’s Internal Control Manual (Version 5) along with its policies and procedures as per relevant appendices?

3. Do you know how to access LSA’s Internal Control Manual (Version 5) along with its policies and procedures as per relevant appendices?
A
B

4. Please indicate where the LSA’s Internal Control Manual (Version 5) along with its policies and procedures as per relevant appendices are electronically saved.

5. Have you been provided a soft copy of LSA’s Code of Ethics and Conduct?

5. Have you been provided a soft copy of LSA’s Code of Ethics and Conduct?
A
B

6. Have you been provided training on LSA’s Code of Ethics and Conduct?

6. Have you been provided training on LSA’s Code of Ethics and Conduct?
A
B

7. Do you know how to access LSA’s Code of Ethics and Conduct?

7. Do you know how to access LSA’s Code of Ethics and Conduct?
A
B

8. Please indicate where LSA’s Code of Ethics and Conduct is electronically saved.

9. Have you been provided a soft copy of LSA’s IT Manual?

9. Have you been provided a soft copy of LSA’s IT Manual?
A
B

10. Have you been provided training on LSA’s IT Manual?

10. Have you been provided training on LSA’s IT Manual?
A
B

11. Do you know how to access LSA’s IT Manual?

11. Do you know how to access LSA’s IT Manual?
A
B

12. Please indicate where LSA’s IT Manual is electronically saved.

13. Have you been provided training on AML/CFT subject-matters?

13. Have you been provided training on AML/CFT subject-matters?
A
B

13 (i) If yes above, please provide the last year in which you attended AML/CFT training?

13 (ii) If No above, please provide details

14. Please indicate the type of FSC licence(s) which LSA holds.

14 (i) According to the FSC licence(s) you mention above, please provide details of the business activities which LSA is allowed to conduct.

15. Please provide the name(s) of the Board of Directors (BOD) of LSA.

16. Please provide the name of the Compliance Officer (CO) of LSA.

17. Please provide the name of the Money Laundering Reporting Officer (MLRO) of LSA.

18. Please provide the name of the Deputy Money Laundering Reporting Officer (DMLRO) of LSA.

19. Please provide the name of the Data Protection Officer (DPO) of LSA.

20. Do you have direct access and contact with the CO/MLRO/DMLRO/DPO of LSA?

20. Do you have direct access and contact with the CO/MLRO/DMLRO/DPO of LSA?
A
B

If No above, please provide details

21. Who is responsible at LSA for ensuring compliance with our Internal Control Manual (Version 5) along with its policies and procedures and with relevant laws, rules and regulations in Mauritius?

22. Who is the direct contact with clients according to LSA’s Internal Control Manual (Version 5) and Organisational Structure Chart?

23. Please list down the KYC documents you will request for onboarding of a private retail client whereby LS Advisors Ltd is managing its assets and portfolios in the following scenarios.

23 (i) Legal Person

23 (ii) Natural Person

24. In case whereby Enhanced Due Diligence measures are required. Please specify which EDD document you will request in the following scenarios.

24 (i) Legal Person

24 (ii) Natural Person

25. Have you onboarded any new clients and/or introducers?

25. Have you onboarded any new clients and/or introducers?
A
B

25 (i) If yes above, please provide names of those onboarded clients and/or introducers.

26. Have you onboarded any clients and/or introducers without the prior approval of the CO?

26. Have you onboarded any clients and/or introducers without the prior approval of the CO?
A
B

26 (i) If yes above, please provide details.

27. Did you proceed with the execution of any agreements between LSA and clients or any other parties?

27. Did you proceed with the execution of any agreements between LSA and clients or any other parties?
A
B

27 (i) If yes, please indicate the name of the agreement and names of parties involved?

28 Did you proceed with the execution of any agreements between LSA and clients or any other parties without the prior approval of the CO?

28 Did you proceed with the execution of any agreements between LSA and clients or any other parties without the prior approval of the CO?
A
B

28 (i) If yes above, please provide details.

29. What is a Politically Exposed Person (PEP)?

29 (i) How would you risk-categorise a PEP? Justify your answer

30. Have any of your clients been identified as a Politically Exposed Person (PEP)?

30. Have any of your clients been identified as a Politically Exposed Person (PEP)?
A
B

If yes above,

30 (i) Please provide details such as full names and country of locations of such PEP clients.

30 (ii) Has the PEP Declaration Form been duly signed by the PEP client?

30 (ii) Has the PEP Declaration Form been duly signed by the PEP client?
A
B

If no above, please provide details.

30 (iii) Has BOD’s approval been obtained prior into entering business relationship with such PEP client?

30 (iii) Has BOD’s approval been obtained prior into entering business relationship with such PEP client?
A
B

If no above, please provide details.

31. Are any of your existing clients and/or business introducers located in sanctioned countries or in the FATF Grey List?

31. Are any of your existing clients and/or business introducers located in sanctioned countries or in the FATF Grey List?
A
B

31 (i) If yes above, please provide the names of such clients/business introducers and their respective jurisdictions of location.

32. Are you involved in any transactions such as payment of invoices, and/or receipt of management and advisory fees?

32. Are you involved in any transactions such as payment of invoices, and/or receipt of management and advisory fees?
A
B

32 (i) Do you seek approval from the MLRO/DMLRO prior to proceed with such payment?

32 (i) Do you seek approval from the MLRO/DMLRO prior to proceed with such payment?
A
B

If No above, please provide details.

32 (ii) Do you inform the MLRO/DMLRO of any receipt of funds?

32 (ii) Do you inform the MLRO/DMLRO of any receipt of funds?
A
B

If No above please provide details.

32 (iii) Do you keep records of the duly signed Outward Bank Transfer Checklist and/or the Inward Bank Transfer Checklist?

32 (iii) Do you keep records of the duly signed Outward Bank Transfer Checklist and/or the Inward Bank Transfer Checklist?
A
B

If No above please provide details.

33. Have you received complaint from your clients?

33. Have you received complaint from your clients?
A
B

If yes above,

33 (i) Please specify if it is a formal or informal complaint?

33 (ii) Please provide details of the nature of complaint?

33 (iii) Is the complainant completely satisfied with the solution?

33 (iii) Is the complainant completely satisfied with the solution?
A
B

If No please provide details.

33 (iv) Have you updated the complaints log?

33 (iv) Have you updated the complaints log?
A
B

If No please provide details.

34. Are you aware of any termination of business relationship between LS Advisors Ltd and its private retail clients?

34. Are you aware of any termination of business relationship between LS Advisors Ltd and its private retail clients?
A
B

34 (i) If yes above, please provide the name of the private retail clients with whom LS Advisors Ltd has terminated business relationship?

35. Are you aware of any termination of business relationship between LS Advisors Ltd and its business introducers/CIF/CGP?

35. Are you aware of any termination of business relationship between LS Advisors Ltd and its business introducers/CIF/CGP?
A
B

35 (i) If yes above, please provide the name of the business introducers/CIF/CGP with whom LS Advisors Ltd has terminated business relationship?

36. Have you witnessed any instances involving suspicion of illegal or dishonest activities observed within LS Advisors Ltd?

36. Have you witnessed any instances involving suspicion of illegal or dishonest activities observed within LS Advisors Ltd?
A
B

If yes above,

36 (i) Please provide details.

36 (ii) Have you reported the case to the Head of Compliance and/or the Board of Directors of LSA?

36 (ii) Have you reported the case to the Head of Compliance and/or the Board of Directors of LSA?
A
B

If No, please provide details

37. Have you witnessed any misconduct of any staff within LS Advisors Ltd?

37. Have you witnessed any misconduct of any staff within LS Advisors Ltd?
A
B

If yes above,

37 (i) Please provide details.

37 (ii) Have you reported the case to HR and/or the Board of Directors?

37 (ii) Have you reported the case to HR and/or the Board of Directors?
A
B

If No please provide details

I, the undersigned, hereby confirm and certify that the above information are hereby provided in good faith and to the best of my knowledge. I take full responsibility for the correctness of the information provided.

Full Names

Job Title

Team

E-mail Address

Signature

Signature