BSA-AML Examiner School Case Study eBook

Internal Use Only

BSA/AML Policy and Program

In addition to the requirements noted above, Critical Third Parties must also fully cooperate with information requests from TS&J for more information on a customer, which may in some cases result from the Bank’s transaction monitoring and investigative activity. Critical Third Parties will handle these requests discreetly and take all available practical steps not to tip off the customer that the Bank may be investigating them. 5. REGULATORY REPORTING AND RECORDKEEPING Currency Transaction Reporting The Bank will file a Currency Transaction Report (“CTR”) with FinCEN on all currency transactions for each cash deposit, withdrawal or exchange of currency totaling more than $10,000. As detailed in the Bank’s CTR procedures, the BSA/AML Officer will establish systems and processes that allow the Bank to: ● Identify all currency transactions (or groups of transactions conducted by or on behalf of the same person during a business day); ● Exempt certain types of customers from currency transaction reporting through a two-phase exemption process; and ● File a CTR with FinCEN within 15 calendar days after the date of the transaction. Purchase and Sale of Monetary Instruments Recordkeeping The Bank will record the identity of individuals purchasing monetary instruments (bank checks or drafts, cashier’s check, bank money orders, or traveler’s checks) with currency between $3,000 and $10,000. In addition, should there be contemporaneous and multiple purchases in one business day totaling $3,000 or more, the Bank will treat it as one purchase. All records concerning the sale or sales will be maintained by the Bank for five years. This is detailed further in the Sale of Monetary Instruments procedures. Funds Transfer Recordkeeping TS&J will collect and maintain records of all funds transmittals valued at $3,000 or more. As detailed in the Bank’s Funds Transfer Procedures, the following information will be included for each such transaction record: ● Name and address of the originator; ● Amount of the payment order;

● Date of the payment order; ● Any payment instructions; ● Identity of the beneficiary’s institution;

24

Confidential