BSA-AML Examiner School Case Study eBook

Internal Use Only

BSA/AML Policy and Program

● Criminal violations over $5,000, when a suspect can be identified; ● Criminal violations over $25,000, regardless of a potential suspect; ● Transactions conducted at, by or through the Bank if the Bank knows, suspects or has reason to suspect that the transactions: ○ Involve potential money laundering or other illegal activity; ○ Are designed to evade the BSA; ○ Have no business or apparent lawful purpose or are not the type of transaction in which the customer would normally be expected to engage, and the Bank knows of no reasonable explanation for the transactions after examining the available facts; or ○ Involves the use of the Bank to facilitate criminal activity. ● Any other suspicious activity that the Bank reasonably believes is relevant to the possible violation of any law or regulation, including cyber events and cyber-related crimes, but is not described above. In any event where an account is not blocked or closed, Bank employees, Fintech Partners, and other Critical Third Parties should document those decisions and seek approval from the BSA/AML Officer or their designee. SAR Timing TS&J will file all SARs in which it can identify a suspect within 30 days of determination of facts that may constitute a basis for reporting that activity is suspicious. In instances where no suspect can be identified within the initial 30 days, TS&J will file SARs within 60 days of such determination. Pursuant to the requirements of 12 CFR Section 208.62(h), the BSA/AML Officer will provide the Board with regular reporting on SARs filed, trends in SAR activity, and notable issues arising from SAR filings. In the event that a SAR identifies a director or executive officer as a suspect, the BSA/AML/OFAC function will ensure the suspect is not notified while notifying all management Risk and Compliance If TS&J has reason to suspect that a customer’s transactions may be linked to terrorist activity, TS&J will immediately call the Financial Institutions Hotline at 1 866- 556-3974. Similarly, if any other suspected violations — such as ongoing money- laundering schemes—require immediate attention, TS&J will notify the appropriate law enforcement agency. These requirements are in addition to filing a SAR, which in either of these circumstances TS&J will do as soon as is practicable. Account Review and Ongoing Filing Committee members who are not suspects. Matters Requiring Immediate Attention

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