BSA/AML Examiner School - Case Study Oct 2023

• List a description of the principal line of business and all types of business operations the customer engages in; • Document whether the customer's business operations is retail vs. wholesale; • For large businesses, provide financial statements and a list of the business's major suppliers and customers; • Document type of products and services used by the customer (i.e., domestic or international wires, cash deposits, ACH transactions, private banking services, etc.) • List details on the source of funds and wealth; • Document the proximity of the customer's residence, place of employment, or place of business to the Bank; • Include a description of the customer's primary trade area and whether international transactions are expected to be routine; • For Non-governmental Organizations, state the purpose and objectives of their stated activities, the geographic locations served (including headquarters and operational area); the organization structure; the donor and volunteer base; funding and disbarment criteria (including basic beneficiary information). • For cash intensive businesses, state the purpose of the account; the volume, frequency and nature of currency transaction; the primary business activity, products and services; geographic locations and jurisdictions of operation; on site visitation. Note: The BSA Department will determine if further enhance due diligence is required after account has been opened and monitored. Overview It is the intent and policy to comply with statutory and regulatory requirements for monitoring, detecting and reporting suspicious activities. The Bank wants to ensure that an effective system for detecting and reporting suspicious activity is established so the proper law enforcement agencies are promptly notified. Note: If any Bank employee becomes aware of any suspicious activity by either a Bank customers or an employee, he/she should promptly report the matter to the BSA Officer. The BSA officer and other staff aware of the matter should keep the information confidential. This policy encourages the reporting of suspicious activity and ensures the employee reporting the incident complete anonymity. The Bank is required to file a Suspicious Activity Report (SAR) for any matter that the Bank has a basis to believe is a known or suspected violation of federal criminal law. The SAR is to be completed in its entirety. The BSA Officer will be the preparer of the SAR and will provide a full description of the suspicious activity and explain any multiple events in chronological order. Only the SAR is to be sent to FinCEN, any supporting documentation will be retained by the Compliance Department. Suspicious Activity Reporting Process Anti-Money Laundering Program System to identify, research, and report suspicious activity All employees are encouraged to refer all unusual activity to the BSA Officer for further research and review the unusual activity. The BSA Officer, along with the Senior Management, will evaluate the IX. Suspicious Activity Report (SAR) Policy and Procedures

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