BSA/AML Examiner School - Case Study Oct 2023

• Monitoring blocked funds, if any. • The BSA/OFAC Officer will file a report on rejected items within 10 days. This report will contain at minimum: The date and amount of the transfer; a photocopy of the payment or transfer instructions received; the basis for rejection; and the name and telephone number of a contact person at the transferee bank from whom compliance information can be obtained. Reports of rejected transfers are to be filed with the Compliance Programs Division office. • The BSA Department will report blocked property to OFAC within 10 days of the date the property is blocked. The reporting requirement for blocked property applies to any form of tangible or intangible property that is blocked pursuant to the OFAC Regulations. The reports are to be transmitted to OFAC Compliance Programs Division and must identify the minimum requirements specified by OFAC. • Total amounts blocked, including interest, will be reported by the Bank to OFAC by September 30 of each year (information as of June 30). Annual reports must be filed using the form entitled "Annual Report of Blocked Property." Blocking/Rejecting Transactions The BSA Department has implemented procedures for handling and reporting transactions that are validly blocked or rejected under the various sanctions’ programs. All staff must make sure that business is not conducted with blocked or specially designated countries, entities or individuals including in the opening of new accounts and in handling wire transfers and other funds transfers. The Bank must block fund transfers that are remitted: • By or on behalf of a blocked individual or entity; • To or through a blocked entity; • In connection with a transaction in which a blocked individual or entity has an interest. If the Bank receives instructions to make a payment that falls into one of these categories, the Bank will execute the payment order/wire transfer and place the funds into a blocked account. A wire transfer cannot be canceled or amended after the Bank has received it. Once assets are blocked, the Bank will release them only by specific authorization from the U.S. Treasury. The Bank will report all blocks to OFAC within 10 days of occurrence. The Bank recognizes that every Bank transaction is potentially subject to a blocking under OFAC regulations. U.S. law requires that assets and accounts be blocked when such property is located in the United States, is held by U.S. individuals or entities, or comes into the possession or control of U.S. individuals or entities. Training It is the policy of the Bank that all personnel receive adequate training on OFAC compliance consistent with our OFAC risk profile and how OFAC compliance relates to an employee's specific responsibilities. OFAC training is provided to all employees of the Bank and it is done in conjunction with the BSA Training. The BSA Department maintains records of all staff training. All Bank employees will receive general training/material on OFAC regulations within 90 days of employment and annually thereafter. The following departments will receive annual training: • Wire transfer • Operations and Lending

For Training Purposes Only

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