Due Diligence
Questionnaire Marketplaces Entity & Ownership

Entity Information

ID	Question	Response
Α.1	Full Legal Name
Α.2	Trading/brand Name (if applicable)
Α.3	Type of Legal Entity
Α.4	Country of incorporation
Α.5	Date of incorporation
Α.6	Registered Address
Α.7	Website Address
Α.8	Please state whether the entity you are representing is a licensed Financial Institution/Payment Services Provider
If yes: please state the Primary Supervisory/Regulatory Authority Name & Country please attach AML CFT related Policies please attach Wolfsberg questionnaire
A.9	Are you acting as commercial agent solely on behalf of the merchants operating through your marketplace?
A.10	Are you acting on your own behalf or on the account of a third party (trustor)?
A.11	In addition to inspections by the government supervisors/regulators, does the Entity have an internal audit function, a testing function or other independent third party, or both, that assesses FCC AML, CTF and Sanctions policies and practices on a regular basis?
Α.12	Key business location/s of operations	Address of operations 1: Address of operations 2: Address of operations 3: Other addresses:
A	Does your institution have physical presence at any of the above addresses?	Yes/No If yes, list of addresses with physical presence:
If no, please state the actual physical address of HQ.
Α.13	Select the business areas applicable to the Entity
Building Association
Insurance
Money Remittance
Payment Account
Money Exchange / FX
Cryptocurrency
Retail Banking
Private Banking / Wealth Management
Commercial Banking
Investment Banking
Transactional Banking
Financial Markets Trading
Securities Services / Custody
Broker / Dealer
Other, please specify:
Α.14	Total Assets in Euro, as of the latest tax declaration or Financial Statements
Α.15	Number of Employees

Commercial Info

ID	Question	Response
B.1	What are the products/services offered?
B.2	Who are your clients? (Consumer, Businesses, both?)
B.3	What is the business focus regarding location?	Domestic/Non-Domestic
B.4	If non-domestic, please choose the areas (i.e., Europe, North America etc.)	□ Europe □ Africa □ N. America □ S. America □ Asia □ Australia □ Middle East □ Far East □ CIS/CEE
B.5	Please, state the industries you work with
B.6	Do you restrict any of the below industries?	□ Gambling □ Arms □ MSB/PSP □ Atomic Power
B.7	Breakdown of the estimated resident, non-resident and offshore clientele	Natural Persons: □ Resident: ___% □ Non-Resident: ___% Corporations: □ Resident: ___% □ Non-Resident: ___% □ Offshore: ___% FIs: □ Resident: ___% □ Non-Resident: ___% □ Offshore: ___%
B.8	Breakdown of estimated client’s structure	Total number of clients: _______ Natural persons: ___% SMEs: ___% Corporations: ___% FIs: ___% Others: ___%
B.9	Please provide figures for: Annual Volume of Transactions (€) Annual number of transactions Est. number of clients Countries where service is provided % of transaction value per country Settlement Currencies
B.10	What brand is displayed in the e-commerce site checkout?
B.11	What brand is displayed in the customer bank statement?
B.12	Who do the Buyers interact for Refunds/Disputes?
B.13	Who performs the delivery of good & services?
B.14	Do your platform host companies they are: Franchises, Travel agents High-Brand Risk Merchants (Gambling, CBD/Vaping/Tobacco, Financial Services, on-line Pharmacies offering prescribed drugs)? Offering Services?
B.15	Can the buyer purchase items/services from multiple sellers during a single checkout?
B.16	Who does the buyer receive a tax receipt from?
B.17	Who receives the customer funds? Marketplace or Seller directly (possible only when purchase includes items from a single seller)?

RISK OF FINANCIAL LOSSES

ID	Question	Response
C.1	Do you accept the liability for all acts, omissions, buyers’ disputes, and other customer service-related issues caused by the merchants?
C.2	Do you have contractual agreement clarifying liabilities and obligations safeguarding your company against financial losses and activity restrictions*, with all your merchants? *activities restrictions are described in Section 13. of VIVA.COM terms and conditions
C.3	Do you have risk management personnel & systems to communicate and settle merchants’ disputes?
C.4	Do you have risk management personnel & systems to minimize risks from merchants’ activities?
C.5	Do you have merchants that accept payments well in advance of delivering their goods or services? If yes, do you have controls to mitigate financial losses that could outcome from Products / Services not Provided Risk?
C.6	Do you have controls on proper monitoring of merchants’ websites to safeguard your company against financial losses and products offering?
C.7	Do you accept Viva.com to perform reviews of your internal controls regarding the mitigation of financial losses?
C.8	Do you have policies and procedures to manage risk of financial losses? Please provide policies and processes Please provide financial statements / annual reports / credit assessments or any other document providing information for the financial status of your company and/or its creditworthiness

Declaration Statement

To be signed by the Group Money Laundering Prevention Officer or Global Head of Anti- Money Laundering or Chief Compliance Officer or Global Head of Financial Crimes Compliance or equivalent).

I, __________________________ (title: ), certify that I have read and understood this declaration, that the answers provided in this questionnaire are complete and correct to my honest belief, and that I am authorised to execute this declaration on behalf of ______________________

_______________________ (Signature & Date)

If you are acting on account of a third party, please provide a list of all trustees (name(s), incl. trust agreement and for legal entities notarized and apostilled extract from commercial register or notarized and apostilled passport copies for private individuals)