BSA-AML Examiner School Case Study eBook

Internal Use Only

BSA/AML Policy and Program

● Take particular care to identify the ownership of all accounts; ● Obtain identifying information from all new account customers and reasonably verify that information using documentary and/or non- documentary methods; ● Obtain evidence of identity from customers seeking to conduct significant business transactions; and ● Identify and verify to the extent reasonable and practicable the identity of beneficial owners of legal entity customers at account opening. Minimum Identifying Information TS&J will obtain the following information (collectively, “CIP Information”) prior to opening an account: ● Full Legal Name; ● Date of Birth (for individuals); ● Physical Address; 5 and ● A government identification number. TS&J will generally collect the customer’s Social Security Number (“SSN”) or Employer Identification Number (“EIN”). 6 Customer Verification The BSA/AML Officer will develop and use risk-based procedures to verify the true identity of each TS&J-Sourced Customer and Fintech Partner-Sourced Customer prior to allowing the customer to transact. The BSA/AML Officer may use non-documentary and/or documentary evidence to verify CIP Information. TS&J will maintain evidence of CIP Information collected and customer verification performed. For documentary methods, TS&J will retain copies of the documentary evidence collected (e.g., a passport, drivers license, or articles of incorporation) and evidence of review performed. For non- documentary evidence, TS&J will retain evidence of reviews performed, including full responses received from verification service providers. TS&J will maintain these records for at least five years after the date on which the account is closed. Customer Due Diligence

5 For business customers this includes a principal place of business, local office, or other physical location. 6 If the customer does not have an SSN/EIN, TS&J will collect an identification number such as a passport number as defined in its procedures.

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Confidential