BSA-AML Examiner School Case Study eBook

Internal Use Only

BSA/AML Policy and Program

PARTY

ROLES AND RESPONSIBILITIES BSA/AML/OFAC compliance initiatives; ● Monitoring corrective action on BSA/AML/OFAC matters and resolving escalated issues; and ● Supporting the BSA/AML Officer on matters relating to audits and examinations.

Business Line Management

Business Line Management is responsible for: ● Promoting a strong culture of BSA/AML/OFAC compliance within their departments;

● Implementing the Policy/Program within their areas of responsibility, including any necessary control activities; ● Notifying the BSA/AML Officer of proposals for new or modified products, services, initiatives, or distribution channels that might affect BSA/AML/OFAC risks; ● Identifying BSA/AML/OFAC compliance weaknesses through monitoring activities, and promptly alerting and working with the BSA/AML Officer to take corrective action; ● Ensuring that their staff receive appropriate BSA/AML/OFAC compliance training; and ● Maintaining systems, controls, and reports used to support BSA/AML/OFAC compliance efforts. All Bank employees are responsible for: ● Complying with and implementing this Policy/Program within their areas of responsibility, including any necessary control activities; ● Completing assigned training related to this Policy/Program; ● Reporting unusual activity to the BSA/AML Officer; ● Escalating potential issues of noncompliance with this Policy/Program; ● Identifying BSA/AML/OFAC compliance weaknesses in their areas of responsibility, and alerting and working with the BSA/AML Officer to take corrective action; ● Notifying the BSA/AML Officer of proposals for new or modified products, services, initiatives or distribution channels; ● Responding to all information requests from the

All Employees

9

Confidential