BSA-AML Examiner School Case Study eBook

A full-service branch was opened in Lincoln, NE in May 2020. Total deposits are approximately $7 million. There is a market president, branch manager and two employees, along with an insurance agent at this location. The activity level at this branch is much less than the other branches. The market president and branch manager are from the area, along with the chairman of the board and several shareholders. The population of Lincoln is around 300,000 and is located in Lancaster County which has a population of just over 325,000. All new customers to TS&J are subject to the CIP procedures. The minimum amount of information obtained for each new customer is name, date of birth, address, TIN and one form of government issued photo ID. The customer’s name is checked against the OFAC list. Total Number of Accounts as of 12-31-2023: DDA-3529, SAV-1845, COD-552, LOANS-649, SERVICED LOANS -569 Number of High-Risk Customers: 17 high, 9 moderate, 8 low Number of Nonresident Alien Customers: 0 Number of PEP or Embassy Customers: Zero Low Moderate X High Comments Stable known customer base.

Customer base increasing due to branching, merger, or acquisition.

A large and growing customer base in a wide and diverse geographic area.

The customer base is well known and has been stable. We have seen a moderate amount of organic customer growth over the last year.

Low X

Moderate

High

Comments

Identified a few high-risk customers and businesses.

Identified a moderate number of high-risk customers and businesses. These may include check cashers, convenience stores, money transmitters, casas de cambio, import or export companies, offshore corporations, politically exposed persons (PEPs),

Identified a large number of high-risk customers and businesses. These may include check cashers, convenience stores, money transmitters, casas de cambio, import or export companies, offshore corporations, PEPs, NRAs, and foreign individuals).

We have a low number of high-risk customers and businesses. The customers we have identified as high risk are reviewed on a consistent basis.

nonresident aliens (NRAs), and foreign individuals).

Low

Moderate X

High

Comments

No transactions with high-risk geographic locations.

Minimal transactions with high-risk geographic locations.

Significant volume of transactions with high- risk geographic locations.

The bank is located in a HIDTA; therefore, this is considered moderate risk. Although we are in a HIDTA, we have not seen any transactions that would be considered drug related.

Products and Services Product and Service Break Down:

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