BSA/AML Examiner School Case Study

Internal Use Only

Additional information is required if the originator sending the wire or beneficiary receiving the wire in the Bank is not an established customer of the Bank; however, the Bank has elected not to do business with non-customers. The Bank does not conduct or accept wire transfers for non-accountholders. Bank acting as an originator's bank For each wire transfer that the Bank accepts as the originator's bank, the Bank must obtain and retain a

record of the following information: • Name and address of originator; • Amount of the wire transfer; • Date of the wire; • Any payment instruction received from the originator/customer with the wire; • Identity of the beneficiary's bank or receiving bank. In addition, the following items should be obtained with the wire transfer: • Name and address of the beneficiary/ receiver of the wire; • Account number of the beneficiary; • Any other specific identifier of the beneficiary. Bank Acting as Beneficiary's Bank

For each wire transfer that the Bank accepts as an intermediary bank, or a beneficiary's bank, the Bank must retain a record of the wire transfer. The wire personnel must ensure that all the Travel Rule Requirements are obtained from the bank sending the wire to our Bank. Note: AJ&R Bank does not process outgoing or incoming wires for non-customers (PUPIDs). Procedures: Funds Transfers A funds transfer is completed by the beneficiary's bank's acceptance of the originator's payment order for the benefit of the beneficiary. When a customer sends a wire, you are the originator's bank. When you receive a wire for your customer, you are the beneficiary's bank. If you merely pass the wire through your wire department to another bank, then you are an intermediary bank (Kentucky Bankers Bank and FED). The BSA requires the Bank involved in funds transfers to collect and retain certain information in connection with funds transfers of $3,000 or more, BSA covers both domestic and foreign transactions and is intended to aid in combating drug trafficking and organized crime. The BSA Department has implemented a process to detect, monitor and report unusua1 and suspicious activities. If you suspect, however, that the person is deliberately breaking up the transfer so that it is less than $3,000, you must report it to the BSA Officer as a structuring attempt. The BSA Department will consider filing a SAR. Recordkeeping Procedures for Banks The following recordkeeping requirements apply to fund transfers: Responsibilities of Originator's Banks- Outgoing Wires The originator's bank (us) must record or retain the following information: • Name and address of the originator (our customer)

For Training Purposes Only

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