BSA-AML Examiner School Case Study eBook

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BSA/AML Policy and Program

PARTY

ROLES AND RESPONSIBILITIES ● Conducting BSA/AML/OFAC oversight of third-party service providers, which includes Fintech Partners ● Maintaining sufficient staffing, both in numbers and qualifications, and appropriate technological resources to implement TS&J’s BSA/AML/OFAC program effectively; ● Ensuring Bank employees and relevant Critical Third Parties, including Fintech Partners, receive BSA/AML/OFAC training and that the Company documents training and attendance; ● Monitoring BSA/AML/OFAC compliance and taking corrective action to remedy any deficiencies found; ● Reviewing changes to BSA/AML/OFAC-related laws, regulations, guidance and ensuring that TS&J implements processes to remain fully in compliance with its BSA/AML/OFAC obligations; ● Reviewing the BSA/AML/OFAC implications of new or changed products, services, initiatives or distribution channels offered by the Bank or its Fintech Partners and advising the management Risk and Compliance Committee and Board on the necessary steps to mitigate BSA/AML/OFAC risk; ● Communicating responsibilities for requirements attributed to the Bank in this Policy/Program to relevant employees and third parties; 2 ● Promptly alerting the Management Risk and Compliance Committee and Board to any material issues of BSA/AML/OFAC non-compliance, and instituting and monitoring corrective actions; and ● Periodically reporting to the management Risk and Compliance Committee and Board on the state of BSA/AML/OFAC compliance, key AML-related metrics (e.g., Suspicious Activity Reports), and any significant ongoing or emerging issues.

Board of Directors (“Board”) 3

The Board is responsible for: ● Reviewing and approving this Policy/Program at least

2 The BSA/AML Officer may communicate responsibilities for third parties, such as Fintech Partners, through their contracts or program agreements. 3 The Board may execute its responsibilities through a Board committee, such as the

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Confidential