BSA/AML Examiner School - Case Study Oct 2023

V. Operations The number of International Wire Transfers is 1, Outgoing Wire Transfers are 91, and Incoming Wire Transfers are 80. The number of customers that originate ACH transactions are Credits (106) and Debits (152). The number of "Higher Risk Customers" are as follows: Non-Bank Financial Institutions, Money Services Businesses, Cash Intensive Business are Rent To Own, Tri-County Animal Clinic, Tri-State Petroleum, World Finance (Exempt), Professional Service Providers, Non Resident Aliens or Foreign Individuals (0), Non-Governmental Organization and Charities, A Comparison of CTRs (100) and SARS (1 in 2013 and amended in 2014), Changes in Bank Management or Employees. The bank accepts ACH debits (176) and credits (349) as well as in house automated payments and transfers. We have several customers that we originate ACH debits and credits for. The bank as of January 31, 2015, has approximately 2268 active accounts. The bank introduced online banking in April 2007 and maintains a web site through FIS. Bill paying service as well as interbank transfers, balance inquires, etc. are offered to our customers. Since the last assessment as of January 31, 2015, the bank has filed an average of 106 currency transaction reports (CTR's) and 1 amended suspicious activity reports (SAR's). CTR's and SAR's are both filed in electronic format at this time. As of the date of this assessment, the bank has two customers exempted from currency transaction reporting (Main Retailers, Inc. and First Finance). We have had several false positive responses to OFAC comparisons but never an actual match. We have also not had any positives to a 314(a) query. VI. OFAC As noted above, the bank has: • A stable, known customer base, • No high risk customers • No overseas branches or even correspondent accounts outside the U.S. • A low volume of wire transfers, and • The bank also has no history of OFAC violations

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