BSA/AML Examiner School - Case Study Oct 2023

AJ & R BANK & TRUST COMPANY

BANK SECRECY ACT/ANTI MONEY LAUNDERING INDEPENDENT TEST REPORT DECEMBER 2015

Table of Contents

Paae

I.

Scope of Independent Test

1

II.

Executive Summary

2

III.

Appendices and Exhibits:

Appendix 1 — BSA Risk Assessment Checklist Index Appendix 2 — BSA Risk Assessment Checklists

8

10 87 88 89

Exhibit 1 — CIP Review

Exhibit 2 — Currency Transaction Reports Exhibit 3 — Wire Transfer Worksheet

Better Bank Corporation does not offer legal advice or opinions to the Bank. BBC employs a consultant who has a Kentucky law license; however, no attorney-client relationship between BBC (or its individual officers or employees) and the Bank has been formed as the result of this engagement. BBC's consultants have not provided legal advice or opinions in connection with this engagement. Any legal questions or concerns should be directed to the Bank's legal counsel. BBC's consultants do not perform bank management functions or make management decisions.

CONFIDENTIAL: This report is strictly confidential and is intended only for the use of the Management and Board of Directors of AJ & R Bank & Trust.