BSA-AML Examiner School Case Study eBook

Internal Use Only

BSA/AML Policy and Program

sharing; ● Establishes a central process for receiving, documenting and responding to PA Section 314(a) and 314(b) requests, and reviews any identified accounts for suspicious activities; ● Promptly evaluates all information sharing requests received and provides timely responses providing all information it is legally allowed to share; ● Considers whether the information sharing request contains information that impacts the customer’s risk level or requires investigation of customer activity; and ● Establishes a central process for making and receiving 314(b) requests. Except under certain defined circumstances, the Bank will not disclose information relating to its SAR filings or transaction monitoring activities to third parties. In particular, TS&J, under no circumstances, will give information to the individuals that the Bank is investigating or on whom the Bank has filed a SAR. The Bank’s policy is that no staff may disclose information about its BSA/AML/OFAC activities or program involving SAR review, preparation or filing without receiving written permission from the BSA/AML Officer. The BSA/AML Officer will ensure that the Bank limits requests to provide customer information pursuant to an information sharing request to the minimum information the Fintech Partner needs to respond to the request. Fintech Partners will cooperate with TS&J’s BSA/AML Officer on all information sharing requests in a transparent and timely manner, maintaining strict confidentiality about the nature and contents of the request. C. MECHANISMS DESIGNED TO MONITOR ONGOING COMPLIANCE 1. STAFFING The BSA/AML Officer will ensure adequate staffing, both in numbers and qualifications, to implement the Bank’s BSA/AML/OFAC program effectively for both the Bank and Critical Third Parties, including Fintech Partners. The BSA/AML Officer will review the adequacy of Fintech Partner staffing as part of initial due diligence and on a periodic basis thereafter through ongoing monitoring. The BSA/AML Officer will present his or her approach to staffing, as needed, to the Board for approval and will ensure that all activities performed on behalf of the Bank comply with Bank policies and procedures and all applicable regulatory requirements regardless of the employees performing the tasks. 2. NEWPRODUCTS AND SERVICES

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Confidential