Introductory BSA/AML Examiner School, Providence, RI

Account does not include: o A product or service where a formal banking relationship is not established with a person; o An account that the bank acquires through an acquisition, merger, purchase of assets, or assumption of liabilities; or o An account opened for the purpose of participating in an employee benefit plan established under the Employee Retirement Income Security Act of 1974. • Customer – Refers to a person that opens a new account; and also an individual who opens a new account for: o An individual who lacks legal capacity, such as a minor; or o An entity that is not a legal person (not a separate legal entity), such as a civic club. Customer does not include: o A financial institution regulated by a Federal functional regulator or a bank regulated by a state bank regulator; o A person described in 31 CFR 103.22(d)(2)(ii)-(iv) that is eligible to be granted a Phase I exemption from currency transaction reporting (i.e., governmental agencies and instrumentalities, and companies that are publicly traded described in the cited paragraph); or o A person that has an existing account with the bank, provided that the bank has a reasonable belief that it knows the true identity of the person. • U.S. Person – Refers to a person who is: o A United States citizen; or o A person other than an individual (such as a corporation, partnership, or trust), that is established or organized under the laws of a State or the United States. Non-U.S. person means a person that is not a U.S. person. Customer Identification Program The first and foremost objective in Anytown Community Bank’s BSA/AML and OFAC initiatives starts with identifying the parties to each account or other financial products and services provided to the customer on an ongoing basis. CIP regulatory provisions require a written program which details how the institution (1) identifies and verifies persons who open new accounts; (2) maintains formal record-keeping to document this process; and (3) cross-checks these activities with government lists. The CIP sub-policy and associated procedures are established to ensure that proper identification is obtained from an individual/entity when establishing the relationship. The CIP procedures are a critical step to ensure that this financial institution does not establish a relationship with an unreliable or criminal party. Anytown Community Bank will develop, implement, and maintain detailed procedures to direct staff in verifying person(s) creating a new customer relationship. The corresponding CIP procedures will specify the types of identifying information to be obtained by staff. Verification procedures will also be created and implemented to verify the accuracy and validity of select account opening documentation provided to the bank. These procedures will be reasonable, practical, and risk-based. The CIP procedures will address requesting the following information: Minimum Customer Identifying Information Required Prior to Opening a New Account: • Legal Name. • Date of Birth (Individuals). • Physical Address: o Place of residence (Individuals). o Principal place of business (Non-individuals). o Persons in the military on active duty – Army Post Office (APO), Fleet Post Office (FPO), or residential or business address of next of kin or other contact individual. Identity Number: U.S. Persons - o Social Security Number (SSN) or other Taxpayer Identification Number (TIN) for an individual. o Employer Identification Number (EIN) or other Taxpayer Identification Number (TIN) for separate legal entities (Corporation, Partnership, Trust, etc.). Non-U.S. Persons – •