BSA/AML Student Exercises Dec. 2022

3. What is your occupation? Are you currently employed? Place of employment? (Note: Be sure to obtain and record the occupation of each account holder.) If the customer is unemployed at the time of account opening, customer must provide their previous employer. 4. What type of items do you expect to be deposited to the account (i.e., cash, check, direct deposit, wires, ACH transactions, etc.)? How frequently will deposits be made? Estimate of anticipated account activity; especially cash activity and wires? 5. What methods do you plan to use to remove funds from the account (checks, ATM, debit card, automated bill payment, etc.)? 6. Will transactions affecting this account originate or have a destination outside the US? 7. What is the source of the funds/assets being deposited or used to open the account? 8. Why did you choose this bank? What other banks do you have accounts with? 9. If business, where is the business organized? Also obtain the county and state registration of business and date of resolution and registration; proof of legal status of the business; if the entity uses fictitious names, obtain documentation containing the customers' real names and other identifying information. Questions Specifically for Consumers to Identify High Risk 1. National origin - In what country are you a citizen? • If the person is a nonresident alien or foreign, it's a high risk. Refer to Enhanced Due Diligence Procedures. 2. Connections to foreign jurisdictions — Are you or any of your relatives or associates connected to the government of a country other than the US? (politically exposed person) • If the person or is related to a politically exposed person, it's a high risk. Refer to Enhanced Due Diligence Procedures. 3. Will the customer's account be under private banking service?. • Private banking relationships will be classified as high risk. Refer to enhanced due diligence procedures. Questions Specifically for Business Customers to identify High Risk 1. Is your business a foreign corporation or an offshore corporation located in tax or secrecy havens, or a domestic shell company, or an international business corporation? • If the answer is yes, the business is a high risk. 2. What is the type of business (cash—intensive business, car sales, import/export, transportation, jewelry dealer, etc.)? Please review the entire list of high risk business, attached to make a final determination. • If the business type matches an entity on the high risk list, the business is a high risk. • Is the business a cash-intensive business (i.e., convenience stores, restaurants, retail stores, liquor stores, etc.)? If the business type matches an entity on the high risk list, the business is a high risk. 3. Will your business be engaging in any of these activities? Check cashing, currency dealing or exchange, money orders, travelers, store value cards, money transfer services (i.e. Western Union). • if the business offers any of these services then the business is considered a Money Service Business (MSB) and should be classified as High Risk. 4. Will the business account be under private banking service? Please review the entire list of high risk business to make a final determination. • Private banking relationships will be classified as high risk.

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