BSA-AML Examiner School Case Study eBook

TS&J BANK

BSA/AML/OFAC Risk Assessment February 2024

Bank Name: TS&J Bank Asset Size: $189 million Number of Employees: 42 FTE’s Holding Company Name: Love Bancshares Employee Turnover Please check one of the following: Low Moderate X

High_

Comments

Low turnover of key personnel or frontline personnel (i.e., customer service representatives, tellers, or other branch personnel).

Low turnover of key personnel, but frontline personnel in branches may have changed.

High turnover, especially in key personnel

Dewitt, VP of Retail/Operations moved in 2023 and subsequently, Ruby Rose, Chief Compliance Officer took on the responsibility in July 2023.

4 Branch Locations in Nebraska Please check one of the following : Low

Moderate X

High

Comments

Offices are not located in a high-intensity drug trafficking area (HIDTA) or high-intensity financial crime area (HIFCA). No fund transfers or account relationships involve HIDTAs or HIFCAs.

Offices are located in a HIDTA or an HIFCA. Bank has some fund transfers or account relationships that involve HIDTAs or HIFCAs.

Offices are located in a HIDTA and an HIFCA. A large number of fund transfers or account relationships involve HIDTAs or HIFCAs.

3 locations are located in a HIDTA. The majority of the customer base are within these areas. The Eagle location is not located in a HIDTA.

Customer Base: Describe the Customer Base (Provide narrative):

TS&J Bank is a community bank that works with its customers face to face and becomes well acquainted with them at or before account opening. This personal interaction creates a customer base that becomes well known in all areas of the bank. The customer base is primarily spread within a 25-mile radius of the four locations. Eagle has nearly 2000 residents but is only 39 miles away from Omaha. Omaha is a large metropolitan city with over 500,000 residents with the MSA having nearly 900,000 residents. The Fremont branch has approximately $30 million in deposits. The customers of the branch are primarily residents in and around the area. This location becomes well acquainted with their customers at and after account opening. Most customers have been with the bank for many years. Population around 3000. It is located in Logan County which has a population of approximately 25,000.

For Training Purposes Only