BSA/AML Student Exercises Dec. 2022

• 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. Refer to Guidance on OFAC Enforcement Policy for a detailed description of detection procedures. • Loans — The best procedure is to compare them against the OFAC list before the loan is funded. • The Bank's systems also check for names on Non-SON lists including the FSE list, SSI list and the NS-PLC list. 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 accounts 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. The Bank should use the following language to provide to customers: "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.

For Training Purposes Only

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