BSA-AML Examiner School Case Study eBook

Operations: CTR Filings

2022 77 2023 _135

Yes _X

CTR Exemptions Utilized

No

The information supporting each designation of a Phase II exempt person is reviewed annually and documented. Phase II exemption accounts are also reviewed annually for suspicious activity.

If yes: Number of Phase I Exempt Customers :13 Number of Phase II Exempt Customers: 4

2022 _9_ 2023 16 2022 0 2023 0 2022 0 2023 0

SAR Filings

314(a) Hits - Positive Responses Reported to FinCEN OFAC Hits – Positive Responses Reported to OFAC Wire Transfer Activity – Total Number of Outgoing Wires Wire Transfer Activity – Number of Outgoing Wires to Foreign Destinations If any were sent to high-risk jurisdictions, provide further detail Marijuana, Hemp & CBD Oils-Low Risk

2022 _1261_ 2023 986

2022 _47 2023 32

International wires primarily involve the same customers who have legitimate international business activity. This continues to be on our radar and is being discussed internally. We have noticed an increase in the number of customers purchasing cryptocurrency and have developed monthly reports to monitor.

No known customers at this time

Cryptocurrency/Bitcoin-Low Risk

Approximately 5 customers making these types of transactions by ACH, wire transfer or debit card.

Privately Owned ATM’s – Low Risk The convenient stores we have as customers do have ATM’s and they are leased

This question is asked on the account opening questionnaire for business accounts and will be monitored.

For Training Purposes Only