BSA/AML Examiner School - Case Study Oct 2023

From: JulieCollins@AJ&Bank&Trust.com Sent: July 13, 2016 To: BSAexaminer@statebankingagency.org Subject: New account/High risk customers

I have uploaded documentation on the new accounts which you requested. I have attached our internal CIP risk rating assessment. We do not have any high risk customer at this time. Let me know if you need anything else.

Julie Collins

BSA Officer AJ& R Bank & Trust JulieCollins@AJ&RBank&Trust.com

From: BSAexaminer@statebankingagency.org Sent: July 13, 2016 To: JulieCollins@AJ&RBank&Trust.com Subject: New account/High risk customer accounts

Julie, I have attached a list of new accounts which I will use as my sample to review your Customer Identification Program procedures, OFAC compliance, and customer due diligence at account opening. Could you upload any account opening documents for each customer, documentation that an OFAC check was performed at account opening, documentation provided to risk rate customers at account opening, and a list of high risk customer accounts.

Thank you, BSA examiner