AMLTF Program and Questionnaire

Summary of National Bank of Canada’s anti-money laundering/anti-terrorist financing program

National Bank of Canada, its subsidiaries and foreign centres (the "Bank") are committed to taking all reasonable and appropriate measures to reduce the risk of its products and services being used for money laundering and terrorist financing ("MLTF") purposes.

The Bank must comply with the regulatory requirements applicable in every jurisdiction in which it operates and with the requirements related to international sanctions in each of these jurisdictions.

The Bank holds itself to high regulatory compliance risk management standards notably to ensure compliance with the requirements of the Proceeds of Crime and Terrorist financing Act and its Regulations, as well as to earn the trust of its clients, its shareholders, the market and the general public.

The Bank’s anti-money laundering/anti-terrorist financing ("AML/ATF") program (the "AML/ATF Program") is the main vehicle for establishing and maintaining effective control of the risk of exposure to MLTF activities throughout the organization. The AML/ATF Program includes the key elements described below:

1. Role of the Board of Directors and oversight by senior management;

2. Senior Vice-President, Chief Compliance Officer and Chief Anti-Money Laundering Officer who is responsible for implementing and updating the AML/ATF Program for regulatory compliance management, regulatory requirements related to AML/ATF and international sanctions;

3. Assessment of inherent proceeds of crime, money laundering and terrorist financing (PCMLTF) risks;

4. Policies and standards that ensure compliance with the regulatory requirements, including those related to AML/ATF and international sanctions;

5. Compliance and AML/ATF training programs for Bank employees, officers, and directors;

6. Independent oversight and monitoring of the AML/ATF Program and the policies and procedures implemented by the Bank to ensure that the control mechanisms are sufficient, respected and effective.

Several key controls, which are outlined in the applicable standards, have been implemented to ensure compliance with regulatory requirements. Here are the main key controls:

1. Know your client (KYC):

✓ Due diligence

✓ Enhanced due diligence

2. Verification and identification:

✓ Screening of designated persons or entities

✓ Client identification

✓ Third party determination

3. Politically exposed persons (PEP)

4. Record keeping

5. Establishing and maintaining business relationships with banks (in connection with correspondent banking activities)

6. Updating client information

7. Oversight of transactions

8. Reporting obligations

9. Document retention in accordance with applicable laws and requirements.

The AML/ATF Program is routinely evaluated, updated and enhanced in order to reflect changes to the Bank’s activities, as well as applicable supervisory standards and legal requirements.

The Correspondent Banking Due Diligence Questionnaire (CBDDQ) completed by the Bank and which describes its AML/ATF practices is available at the following link: click here . We recommend consulting the Bank’s CBDDQ. It should cover the questions of your financial institution’s AML questionnaire.