wolfsberg questionnaire.pdf

the Wolfsberg Group

Financial Institution Name:
Location (Country) :

Benefit Street Partners Limited
United Kingdom

No # Question	Answer
1. ENTITY & OWNERSHIP
1	Full Legal name
2	Append a list of foreign branches which are covered by this questionnaire (if applicable)
3	Full Legal (Registered) Address
4	Full Primary Business Address (if different from above)
5	Date of Entity incorporation/establishment
6	Select type of ownership and append an ownership chart if available
6 a	Publicly Traded (25% of shares publicly traded)
6 a1	If Y, indicate the exchange traded on and ticker symbol
6 b	Member Owned/Mutual
6 c	Government or State Owned by 25% or more
6 d	Privately Owned
6 d1	If Y, provide details of shareholders or ultimate beneficial owners with a holding of 10% or more
7	% of the Entity's total shares composed of bearer
8	Does the Entity, or any of its branches, operate under an Offshore Banking License (OBL)?
9	Does the Bank have a Virtual Bank License or provide services only through online channels?
10	Provide Legal Entity Identifier (LEI) if available
2. AML, CTF & SANCTIONS PROGRAMME
11	Does the Entity have a programme that sets minimum AML, CTF and Sanctions standards regarding the following components:
11 a	Appointed Officer with sufficient experience/expertise
11 b	Adverse Information Screening
11 c	Beneficial Ownership
11 d	Cash Reporting
11 e	CDD
11 f	EDD
11 g	Independent Testing
11 h	Periodic Review
11 i	Policies and Procedures
11 j	PEP Screening
11 k	Risk Assessment
11 l	Sanctions
11 m	Suspicious Activity Reporting
11 n	Training and Education
11 o	Transaction Monitoring
12	Is the Entity's AML, CTF & Sanctions policy approved at least annually by the Board or equivalent Senior Management Committee?
13 a	Components of its AML, CTF & Sanctions programme? If Y, provide further details
14	Does the entity have a whistleblower policy?
3. ANTI BRIBERY & CORRUPTION
16	Consistent with applicable ABC regulations and requirements to reasonably prevent, detect and report bribery and corruption?
17	Does the Entity provide mandatory ABC training to:
17 a	Board and Senior Committee Management
17 b	1st Line of Defence
17 c	2nd Line of Defence
17 d	3rd Line of Defence
17 e	Third parties to which specific compliance activities
17 f	Non-employed workers as appropriate (contractors/consultants)
4. AML, CTF & SANCTIONS POLICIES & PROCEDURES
18	Has the Entity documented policies and procedures consistent with applicable AML, CTF & Sanctions regulations and requirements to reasonably prevent, detect and report:
18 a	Money laundering
18 b	Terrorist financing
18 c	Sanctions violations
19	Does the Entity have policies and procedures that:
19 a	Prohibit the opening and keeping of anonymous and fictitious named accounts
19 b	Prohibit the opening and keeping of accounts for unlicensed banks and/or NBFIs
19 c	Prohibit dealing with other entities that provide banking services to unlicensed banks
19 d	Prohibit accounts/relationships with shell banks
19 e	Prohibit dealing with another Entity that provides services to shell banks
19 f	Prohibit opening and keeping of accounts for Section 311 designated entities
19 g	Prohibit opening and keeping of accounts for any unlicensed/unregulated remittance agents or money transfer agents
19 h	Assess the risks of relationships with domestic and foreign PEPs
19 i	Define the process for escalating financial crime risk issues/potentially suspicious activity identified by employees
19 j	Outline the processes regarding screening for sanctions, PEPs and Adverse Media/Negative News
20	Has the Entity defined a risk tolerance statement that defines a risk boundary around their business?
21	Does the Entity have record retention procedures that comply with applicable laws?
21 a	If Y, what is the retention period?
5. KYC, CDD and EDD
22	Does the Entity verify the identity of the customer?
23	Do the Entity's policies and procedures set out when CDD must be completed?
24 a	Customer identification
24 b	Expected activity
24 c	Nature of business/employment
24 d	Ownership structure
24 e	Product usage
24 f	Purpose and nature of relationship
24 g	Source of funds
24 h	Source of wealth
25	Are each of the following identified:
25 a	Ultimate beneficial ownership
25 b	Authorised signatories (where applicable)
25 c	Key controllers
25 d	Other relevant parties
27	Does the due diligence process result in customers receiving a risk classification?
28	Does the Entity have policies, procedures and processes to review and escalate potential matches?
29	Is KYC renewed at defined frequencies based on risk rating?
29 a	If yes, select all that apply:
29 a1	Less than one year
29 a2	1 – 2 years
29 a3	3 – 4 years
29 a4	5 years or more
29 a5	Trigger-based or perpetual monitoring reviews
30	From the list below, which categories of customers or industries are subject to EDD or restricted?
30 a	Arms, Defence, Military
30 b	Respondent Banks
30 c	Embassies/Consulates
30 d	Extractive industries
30 e	Gambling customers
30 f	General Trading Companies
30 g	Marijuana-related Entities
30 h	MSB/MVTS customers
30 i	Non-account customers
30 j	Non-Government Organisations
30 n	PEPs
30 o	PEP Close Associates
30 p	PEP Related
30 t	Shell banks
6. MONITORING & REPORTING
33	Does the Entity have risk based policies, procedures and monitoring processes for the identification and reporting of suspicious activity?
34	Does the Entity have regulatory requirements to report suspicious transactions?
34 a	If Y, does the Entity have policies, procedures and processes to comply with suspicious transactions reporting requirements?
35	Does the Entity have policies, procedures and processes to review and escalate matters arising from the monitoring of customer transactions and activity?
7. PAYMENT TRANSPARENCY
36	Does the Entity adhere to the Wolfsberg Group?
37 a	Does the Entity have policies, procedures and processes to comply with and have controls in place to ensure compliance?
38	Does the Entity have a Sanctions Policy approved by management regarding compliance with sanctions law?
39	Does the Entity have policies, procedures or other controls reasonably designed to prohibit and/or detect actions taken to evade applicable sanctions prohibitions?
40	Does the Entity screen its customers against Sanctions Lists?
41 a	Consolidated United Nations Security Council Sanctions List (UN)
41 b	United States Department of the Treasury's Office of Foreign Assets Control (OFAC)
41 c	Office of Financial Sanctions Implementation HMT (OFSI)
41 d	European Union Consolidated List (EU)
41 e	Lists maintained by other G7 member countries
41 f	Other (specify)
42	Does the Entity have a physical presence in countries/regions against which sanctions have been enacted?
9. TRAINING & EDUCATION
43	Does the Entity provide mandatory training?
43 a	Includes identification and reporting of transactions to government authorities
43 b	Examples of different forms of money laundering and terrorist financing
43 c	Internal policies for controlling money laundering
43 d	New issues occurring in the market
44	Is the above mandatory training provided to:
44 a	Board and Senior Committee Management
44 b	1st Line of Defence
44 c	2nd Line of Defence
44 d	3rd Line of Defence
44 f	Non-employed workers (contractors/consultants)
10. AUDIT
45	Does the Entity have an internal audit function or other independent third party that assesses FCC AML, CTF, ABC, Fraud and Sanctions policies and practices on a regular basis?
Signature Page	Wolfsberg Group Financial Crime Compliance Questionnaire 2023 (FCCQ V1.2)

Benefit Street Partners Limited _______________________________________________________________________________ (Financial Institution name)
Ben Woodley (MLRO and Head of Compliance)
I certify that the answers provided in this Wolfsberg FCCQ are complete and correct to my honest belief.
4/30/2026 6:37 AM PDT
______________________________________________ (Signature & Date)