BSA/AML Examiner School - Case Study Oct 2023

LCB 12/15

Board of Directors Meeting Minutes — The Board meets on a monthly basis. Board minutes from December 2014 through November 2015 were reviewed. BBC included suggestions in the Executive Summary portion of this report regarding enhancement of the reporting to the Board to ensure it is fully informed regarding the Bank's program and associated risks. Compliance Committee Minutes — The Bank does not have a formal Compliance Committee. Audit Committee Minutes — Minutes from the 9/18/2015, 10/29/2015, and 11/20/2015 were reviewed. Electronic Cash - Request list responses indicate that the Bank does not sell pre-paid access cards. Private Automated Teller Machines — Request list responses indicate that the Bank does not have any customers who maintain private ATMs. Non-Deposit Investment Products (NDIPs) — Request list responses indicate that the Bank does not offer NDIPs. Trust Department — Request list responses indicate that the Bank does not have a Trust Department. Insurance — Request list responses indicate that the Bank does not own an insurance company. Bulk Currency Shipments — Request list responses indicate that the Bank does not have customers that transact bulk currency shipments.

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