BSA/AML Examiner School Case Study

Internal Use Only

"IMPORTANT INFORMATION ABOUT PROCEDURES FOR OPENING A NEW ACCOUNT" "When you open an account, we will ask for your name, address, date of birth and other information that will allow us to identify you. We will also ask to see your driver's license or other identifying documents. These requirements are...Required by the Patriot Act; Intended to help combat terrorism and other attempts to use our country's financial systems for illegal purposes; designed to help protect you from identity theft." 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; • A description of any document that was relied upon pursuant to this policy that clearly evidences the type of document and any identification number it may contain; • A description of the methods and results of any measures undertaken to verify the identity of a customer pursuant to this policy; and • A description of the resolution of any substantive discrepancy discovered when verifying the identifying information obtained. The Bank will also retain a list of each individual containing the name, address and account numbers of those members whom the Bank has been unable to secure taxpayer identification number from that person after making reasonable effort to obtain the number. The Bank will retain all documentation related to the identity verification of customers for a period of five years after the account is closed. XI. Customer Due Diligence and Enhanced Due Diligence Policy and Procedures It is the intent and policy of the Bank to have a clear and concise understanding of all Bank customer practices in order to avoid criminal exposure to the Bank by any "customer" who would use the Bank's resources for illicit purposes. The objective of the policy and procedures implemented by the Bank is to ensure the immediate detection and identification of suspicious activity at the Bank and to identify those customers that may pose higher risk for money laundering or terrorist financing. Customer Due Diligence , or best described as "Know Your Customer", is a process of obtaining information at account opening and during the life of the account that helps the Bank in identifying potentially high risk customers. Once those customers are identified, they become subject to Enhanced Due Diligence. The goal of Customer Due Diligence is to identify high risk customers that may require Enhanced Due Diligence. Review the list below of 'Customers and Entities of Interest" that will need Enhanced Due Diligence at account inception or after account has been opened. Enhanced Due Diligence (EDD) includes extraordinary questions because the person or entity has been identified as subject to expanded review procedures. Information sought is needed to more specifically predict account activity and increase the Bank's comfort level with the relationship. List of High Risk Customers:

For Training Purposes Only

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