BSA/AML Examiner School Case Study

Internal Use Only

• Determine and document the purpose of account; • For Money Services Business (MSB), confirm FinCEN registration, if applicable (registration must be renewed every two years); • For MSB, confirm state licensing, or agent status, if applicable; • For MSB, the BSA Department will determine the level of risk associated with each MSB account and whether further enhance due diligence is required after account has been opened. Note: Refer to the Money Service Business (MSB) Guidelines for more details on MSB requirements. Professional Service Providers (Doctors, Attorneys, etc.) Procedures Account officer should make reasonable efforts to document and obtain (in the system or in a memorandum) the following. Any memorandums should be sent to the BSA Officer. • Identify and document the intent of the account; • Document the anticipated transaction volume; • List the type of products and services used by the customer (i.e., domestic or international wires, cash deposits, ACH transactions, private banking services, etc.); • identify and list the geographic locations involved in the relationship; • Ensure the Bank has obtained all proper identification for all signers and /or owners; • Ensure all proper documentation is obtained for interest on Lawyer's Trust Account (IOLTA). See IOLTA Cheat sheet. Private Banking Due Diligence Program (Non-US Persons) A private banking account is an account (or any combination of accounts) maintained at the Bank that satisfies all three of the following: 1. Requires a minimum aggregate deposit of funds or other assets of not less than $1,000,000; 2. Is established on behalf of or for the benefit of one or more non-U.S. persons who are direct or beneficial owners of the account; and 3. Is assigned to, or is administered or managed by, in whole or in part, an officer, employee or agent of a covered financial institution acting as a liaison between the covered financial institution and the direct or beneficial owner of the account. Enhanced Customer Due Diligence-EDD If you have identified a High Risk Customer during account opening, you should review all required items under Private Banking Enhanced Due Diligence. The Bank has established these Private Banking Due Diligence procedures to detect and report any suspicious activity conducted through or involving any private banking account that is established, maintained, administered, or managed in the United States by the Bank. Account officer should make reasonable efforts to document and obtain (in the system or in a memorandum) the following additional information. Any memorandums should be sent to the BSA Officer. • Determine and document the identity of all nominal and beneficial owners of a private banking account. The Bank must have proper identification for all accountholders. • Determine and document whether any person identified is a senior foreign political figure. If the Non Residential Alien (NRA) is a "Politically Exposed Persons", be sure to advise the BSA Officer and follow the enhanced due diligence for Politically Exposed Person.

For Training Purposes Only

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