BSA/AML Examiner School - Case Study Oct 2023

• Any confession, admission or explanation provided by the suspect or any person who benefited from the transaction; • Evidence of any cover-up or attempts to deceive federal or state examiners or others; • The Bank will maintain documentation of all suspicious activity investigations, regardless of whether a SAR was filed. X. Currency Transaction Reporting (CTR) Policy and Procedures Overview A CTR form must be completed if all cash transactions by one person totals more than $10,000 in one banking day or cash transactions aggregate to more than $10,000. The system will produce a CTR when the transaction(s) received are MORE Than $10,000 or have aggregated to MORE than $10,000. It is the responsibility of the staff member processing a transaction to obtain the required information prior to completing the transaction. Not only is the identity of the person conducting the transaction required, but also the identity of any person or entity on whose behalf the transaction is being conducted. CTR Verification The CTRs will be reviewed for accuracy and completeness by the BSA Officer before final submission to the IRS reporting center. However, the employee processing the transaction and their supervisor are ultimately responsible for the general accuracy and completeness of the form. An incomplete CTR will be returned to the branch for immediate revision and resubmission to the BSA Officer. Filing Timeframes and Record Retention Requirements All completed CTRs are filed with FinCEN within 15 days after the date of the transaction. Copies of CTRs must be retained for 5 years from the date of the report. Monitoring Cash Activity Reports assist the BSA Department to monitor all transactions needing a CTR and also identify suspicious currency activity, such as the following examples: 1. Currency activity including multiple transactions greater than $10,000; 2. Currency activity (single and multiple transactions) below the $10,000 reporting requirement (i.e., between $5,000 and $10,000); 3. Currency transactions involving multiple lower dollar transactions (i.e., $3,000) that over a period of time aggregate to a substantial sum of money (i.e., $30,000); or 4. Currency transactions aggregated by customer name, tax identification number or customer information file number. These reports identify and evaluate unusual currency transactions. However, all employees are encouraged to report any unusual cash activity. The BSA Department will investigate the issue further. Note: Please alert the BSA Officer, in the event the customer, after becoming aware that a report may be filed because identifying information has been requested, declines to follow through with a transaction which has already been initiated. Proper documentation needs to be kept on this type of occurrence. XI. Currency Transaction Reporting Exemption Policy and Procedures

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