BSA-AML Examiner School Case Study eBook

Internal Use Only

BSA/AML Policy and Program

● As many of the following items as are received with the payment order: ○ Name and address of the beneficiary; ○ Account number of the beneficiary; and ○ Any other specific identifier of the beneficiary. The records of these funds transfer activities will be maintained by the Bank for five years. Reports of International Transportation of Currency or Monetary Instruments (CMIRs) The Bank does not plan to undertake any activities that would involve transporting, mailing or shipping monetary instruments out of or into the United States in any amount. If in the future the Bank develops plans to allow other types of transfers that might trigger a CMIR filing requirement, the BSA/AML Officer will ensure that the Bank develops reporting procedures in advance of the transfer activity commencing. Reports of Foreign Banks and Financial Accounts (FBARs) While the Bank does not plan on activities that will involve FBARs, the Bank will file an FBAR with FinCEN in any circumstances in which it has maintained a foreign account or accounts where the aggregated balances exceed $10,000 in a calendar year by April 15. 6. INFORMATION SHARING TS&J will cooperate fully with federal government authorities, law enforcement authorities, and other U.S. financial institutions on BSA/AML/OFAC investigations to the extent allowable under applicable privacy and other laws. In particular, the Bank will respond promptly to: ● Patriot Act (“PA”) Section 314(a) requests from FinCEN; ● PA Section 314(b) requests from other financial institutions that TS&J has established follow PA 314(b) requirements; ● Special Measures published under PA Section 311 from the Secretary of the Treasury; and ● Any other requests from government agencies, including subpoenas and National Security Letters. The BSA/AML Officer will establish systems and procedures to ensure that the Bank: ● Notifies FinCEN of the Bank’s intent to participate in PA Section 314(b)

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