BSA-AML Examiner School Case Study eBook

Internal Use Only

BSA/AML Policy and Program

employees are trained on red flags relevant to TS&J’s business. The BSA/AML/OFAC function will also set up systems to review customers and activity that is the subject of law enforcement requests and subpoenas. In relation to Third-Party Sourced Customers, the BSA/AML Officer will ensure that there is an appropriate level of automated monitoring between TS&J and each Fintech Partner. TS&J will also require Fintech Partners to escalate unusual activity for review by TS&J Compliance. TS&J’s transaction monitoring processes will include rules or scenarios designed to identify: ● Unusually large transactions; ● Unusually frequent transactions; ● Structuring transactions to avoid actual or perceived reporting thresholds, both within one account and (to the extent applicable) across multiple linked accounts; ● Groups/patterns of transactions indicative of smurfing; ● Groups/patterns of transactions indicative of layering; ● Unusual velocity of transactions; ● Concentrations of customers with similar characteristics (e.g., SSN/EIN, address); ● Fraudulent or potentially fraudulent transactions; ● Evidence of illegal activity; and ● Other rules or scenarios the BSA/AML Officer determines are necessary to manage the Bank’s risks. The results of the BSA/AML/OFAC risk assessment will inform TS&J’s transaction monitoring program and the BSA/AML Officer will ensure that the Bank’s transaction monitoring addresses the risks posed by its products and services, customers, and geographies. The BSA/AML Officer will ensure that TS&J conducts end-to-end pre- and post-implementation testing of transaction monitoring rules, including any changes to scenarios or thresholds. The BSA/AML Officer will ensure that all Bank employees receive training on how to report suspicious activity to appropriate Bank staff as part of the BSA/AML/OFAC training program. Investigations The BSA/AML Officer will oversee investigative procedures and processes that ensure all alerts are investigated in a timely manner in order to meet the timing

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Confidential