BSA/AML Examiner School - Case Study Oct 2023

Overview It is the policy of the Bank to comply with statutory and regulatory requirements of all purchases and sales of monetary Instruments for currency in amounts between $3,000 and $10,000. The records of monetary instruments sales must be retained for 5 years and be available to the appropriate agencies upon request. The objective of this policy and procedures is to ensure the following: • Maintain a chronological log for each month of the sale of all Cashier's checks, which were purchased for currency in the amount of $3,000 to $10,000. The Bank must maintain a record of each cashier’s check, purchased for $3,000 or more in cash. • Name of purchaser; physical address of purchasers; • Social security number of purchaser or alien identification number; • Date of birth of purchaser; • Date of purchase; type(s) of instrument purchased; • Amount in dollars of each of the instrument(s) purchased; • Serial number(s) of the instrument(s) purchased; • Description of document or method used to verify the name and address of the purchaser. Overview The Bank is required to maintain certain records on funds transfers of more than $3,000. All records must be maintained for 5 years. Incoming and outgoing wire transfers should only be processed for established customers of AJ&R Bank. Procedures have been set to adhere with the following: The information required to be obtained and maintained depends on the Bank's role in the particular funds transfer (originator's bank, intermediary bank, or beneficiary's bank). The requirement may vary depending on whether an originator or beneficiary is an established customer of the Bank and whether payment order is made in person or otherwise. Additional information is required if the originator sending the wire or beneficiary receiving the wire in the Bank is not an established customer of the Bank; however, the Bank has elected not to do business with non-customers. The Bank does not conduct or accept wire transfers for non-accountholders. Bank acting as an originator's bank For each wire transfer that the Bank accepts as the originator's bank, the Bank must obtain and retain a The Bank does not sell any monetary instrument to non-customers. XIII. Funds Transfer Recordkeeping Policy and Procedures

record of the following information: • Name and address of originator; • Amount of the wire transfer; • Date of the wire; • Any payment instruction received from the originator/customer with the wire; • Identity of the beneficiary's bank or receiving bank.

For Training Purposes Only

Page 13