BSA-AML Examiner School Case Study eBook

Internal Use Only

BSA/AML Policy and Program

TS&J will collect additional customer due diligence (“CDD”) information at the time of onboarding as needed to: ● Support the CIP; ● Inform customer risk ratings; and ● Provide a basis of customer information needed to support the BSA/AML/OFAC program more generally. Additional CDD information will vary according to the type of customer, as further defined in TS&J’s internal procedures. Beneficial Owners With respect to legal entities, TS&J will collect CIP Information with respect to each beneficial owner defined in Section 4 above. TS&J will use the customer verification processes described above to verify the identity of such beneficial owners prior to allowing the customer to transact. Failure to Validate Identity If TS&J does not receive satisfactory evidence of a customer’s identity, it will not permit the customer to transact. Additionally, cases where non-provision of identity information may itself be an AML red flag will be referred for investigation and consideration of whether TS&J needs to file a suspicious activity report (“SAR”). Notice to Customers TS&J will provide customers with adequate notice that the Bank is requesting information to verify their identities, as required by the U.S. Treasury’s Financial Crimes Enforcement Network CIP Rule (“CIP Rule”) and will provide it in a manner that is reasonably designed to allow a customer to view it or otherwise receive it before the account is opened. The notice will read as follows: “To help the government fight the funding of terrorism and money laundering activities, Federal law requires all financial institutions to obtain, verify, and record information that identifies each person who opens an account. What this means for you: When you open an account, we will ask for your name, address, date of birth, and other information that will allow us to identify you. We may also ask to see your driver's license or other identifying documents.” Customer Risk Rating TS&J will develop and maintain a Customer Risk Rating Methodology , which will be used to determine the level and frequency of due diligence required for each

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Confidential