BSA-AML Examiner School Case Study eBook

Internal Use Only

BSA/AML Policy and Program

customer. TS&J will promptly risk rate all customers after onboarding. This methodology will, at a minimum, take into account: risk factors identified in due diligence of the customer and related parties such as beneficial owners; products and services utilized; activity of the customer (e.g., transaction volumes); and outputs from CIP, transaction monitoring, and other internal controls associated with the BSA/AML/OFAC program. The Customer Risk Rating Methodology will also identify any categories of customers that are automatically high risk and require EDD prior to onboarding. The Customer Risk Rating Methodology will also set out standards and processes for: ● Ongoing update of customer risk ratings; ● Conduct of EDD; and ● Risk-based update of CIP Information. Enhanced Due Diligence TS&J will conduct EDD on those customers or transactions where the customers or transactions pose higher money laundering and/or terrorist financing risks owing to the customer’s business activity, ownership structure, and anticipated or actual volume and types of transactions. The BSA/AML Officer will adopt a risk based, tiered approach to EDD. Customers that remain high risk will remain subject to an EDD refresh process on at least an annual basis. TS&J will document the results of all EDD activity. To the extent that EDD identifies suspicious or unexplained activity, the BSA/AML Officer will consider what action to take, which may include some or all of the following: ● Additional ongoing monitoring; ● Consideration of whether to file a SAR; ● Closure of the account; and/or ● Other measures deemed appropriate by the BSA/AML Officer. Prohibited Customers and Customer Offboarding TS&J maintains a list of prohibited customer types and a list of customers that are ineligible to open new accounts, including associated procedures for keeping these lists up to date. In relation to previously offboarded customers and prohibited customer types that can be identified from basic customer information, TS&J maintains automated screening that generates alerts for review and decisioning by BSA/AML/OFAC compliance staff. TS&J identifies other types of prohibited customers through manual KYC review processes. TS&J will not onboard

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Confidential