BSA-AML Examiner School Case Study eBook

Internal Use Only

BSA/AML Policy and Program

● Integration is the end goal of money laundering, involving the incorporation of unlawful proceeds into the financial system to convert illicit funds into apparently legitimate business earnings.

Program

Procedures and controls by which TS&J will comply with its BSA/AML/OFAC obligations.

Sanctions

Commercial and financial penalties applied by one or more countries against a targeted country, regime, or individual(s) for national security or foreign policy reasons. For purposes of this Policy/Program, Sanctions refers to such measures imposed by the United States government and implemented and enforced by the Office of Foreign Assets Control (“OFAC”). Sanctions often include prohibitions against U.S. persons engaging in certain trade or financial transactions and other dealings.

Willful Blindness

Knowingly “turning a blind eye” to a potential money laundering violation.

5. GOVERNANCE, ROLES, AND RESPONSIBILITIES

PARTY

ROLES AND RESPONSIBILITIES

BSA/AML Officer 1

The BSA/AML Officer is the Policy Owner and is responsible for: ● Drafting, implementing, and maintaining this Policy/Program; ● Reviewing the Policy/Program, procedures, and risk assessment at least annually, and more frequently as circumstances require, and making changes as needed with appropriate reporting; ● Overseeing the implementation of the BSA/AML/OFAC Policy/Program, including providing guidance and direction to Bank employees and Fintech Partners about the steps they need to take to help ensure the success of the Bank’s BSA/AML/OFAC program in their areas of responsibility;

1 The BSA/AML Officer may also be the Chief Compliance Officer.

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Confidential