BSA-AML Examiner School Case Study eBook

Internal Use Only

BSA/AML Policy and Program

● Ensures the Bank documents efforts to meet its legal and regulatory obligations; ● Provides a training program for Bank employees; ● Requires independent testing of its BSA/AML/OFAC program; ● Requires periodic reporting to TS&J’s Risk and Compliance management committee and Board on the Bank’s BSA/AML/OFAC efforts; and ● Specifies how the Bank will oversee the AML programs of its Third Parties. 3. SCOPE This Policy / Program applies to all Bank employees. To the extent the Bank outsources any activities related to this Policy / Program to a third party, including an affiliate, independent contractor, vendor, or Fintech Partner, this Policy / Program also applies to the third party. 4. KEY TERMS

TERM

DEFINITION

BaaS Solutions Platform

The BaaS Solutions Platform is the Bank’s BaaS platform that will offer partner bank capabilities and strategic partnerships with Fintech Partners to deliver banking products and services to businesses and consumers across the United States. Each individual, if any, who, directly or indirectly, through any contract, arrangement, understanding, relationship, or otherwise, owns 25 percent or more of the equity interests of a legal entity customer; and a single individual with significant responsibility to control, manage, or direct a legal entity customer, including: ● An executive officer or senior manager (e.g., a chief executive officer, chief financial officer, chief operating officer, managing member, general partner, president, vice president, or treasurer); or ● Any other individual who regularly performs similar functions.

Beneficial Owner

BSA/AML/ OFAC

The BSA, other AML laws and regulations, and sanctions law and regulations. See Section 10.B for additional information.

BSA/AML/

The risk of legal or regulatory sanctions, material financial loss, or loss to reputation that the Bank may suffer as a result of the

TERM

DEFINITION

4

Confidential