BSA/AML Examiner School - Case Study Oct 2023

Verifying Account Opening Documentation (Documentary and non-Documentary verification.) • The identifying information must be verified before the account is opened. Inspect the documentation and compare the photograph and the description on the ID with the person presenting the document. • In general, two forms of identification are required to open an account. This includes a primary and a secondary piece of identification or a non-documentary verification. • In addition, signatures should be compared from the identification to the signature provided by the customer on the Bank's loan application or signature cards. • If the bank is not able to verify the true identity of the customer through documents, the account must be closed. This action should take no longer than 10 business days from the start of the application or opening of the account. • Awaiting TIN or SSN — For deposit accounts, have the customer certify his/her social security number (SSN) or taxpayer identification number (TIN) on IRS Form W9 or the signature card. If the customer does so, this procedure is complete. If the customer has applied for, but not received, TIN or SSN, the account but be postponed until the customer can provide all required documentation. • Missing Documents — If the customer does not have all of the required identification and information, the account cannot be opened until the customer can supply the required information. • On accounts that we open where we are not familiar with the documents —When the employee is unfamiliar with the documents produced, the customer must be directed to apply for a valid identification card issued by the state or other valid government issued document. Opening Accounts When the Customer Is Not Present at the Bank (Accounts Opened by Mail, Telephone, or via the Internet) • AJ&R Bank DOES/DOES NOT open accounts by Mail, Telephone, or via the Internet. • All person(s) must be present at the time of account opening. Comparison with Government Lists • All new customer names and existing customer names must be verified against the OFAC list provided by FIS. The FIS Software/OFAC Tracking System will automatically do an initial screening of new accounts (CIF input). You are responsible to review the results. If a customer does appear on the OFAC System (OFAC.CIFM_307.PDF), The BSA Officer should be notified IMMEDIATELY in order to properly document and notify the respective government agency. • Loans — The best procedure is to compare them against the OFAC list before the loan is funded. Customer Notification The bank will notify new customers about these procedures by posting signs in the lobby and displaying table tents at each desk where accgvounts are opened or loan applications are provided, notifying customers that we will be requesting information to verify their identity. The customer is provided with adequate notice of the Bank's requirement to verify a customer's identity prior to opening an account. Recordkeeping The Bank shall keep records of the information required and the type of documentary and non documentary records obtained during the identification and verification process. As outlined in the law the following information will be required: • All identifying information provided by a customer after the date the account is closed or becomes dormant;

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