BSA/AML Student Exercises Dec. 2022

bank has a representative in the US, or in a foreign country pursuant to any mutual legal assistance treaty, multilateral agreement or other request for international law enforcement assistance. Upon receipt of a written request from a Federal law enforcement officer for information required to be maintained by the Bank, it is the responsibility of the Senior Management and the BSA Officer to provide the information to the requesting officer no later than 7 days after receipt of the request. It is the policy of the Bank to terminate any correspondent relationship with a foreign bank no later than 10 business days after receipt of written notice from the Secretary or the Attorney General that the foreign bank has failed: • To comply with a summons or subpoena issued; or • To initiate proceedings in a United States court contesting such summons or subpoena. Record Retention The following are the records the Bank must keep from all correspondent accounts. As with all other records, the Bank must keep for the life of the account and for five years after the account is closed: • Due diligence checklists (or similar documentation). • Financial transaction records associated with each correspondent account. • Reports submitted to government authorities concerning suspicious correspondent account activity (suspicious activity reports). • If applicable, Records of all AML training sessions conducted, including the names and business units of attendees and the dates and locations of the training sessions. • The BSA/OFAC Officer will retain the original of any document provided by a foreign bank, and the original or a copy of any document otherwise relied upon by the Bank for at least 5 years after the date that the Bank maintains any correspondent account for such foreign bank. Politically Exposed Persons (PEP) and Enhanced Customer Due Diligence It is the policy of the Bank to obtain sufficient information to determine whether an individual is a PEP in determining the acceptability of high dollar or high risk accounts. For example, when conducting due diligence on a high dollar or high risk account, it is the responsibility of the bank officer to review a customer's income sources, financial information and professional background. These factors will likely require review of past and present employment, as well as general references that may identify a client's status as a PEP. The term "politically exposed person" (PEP) generally includes a current or former senior foreign political figure, their immediate family and their close associates. More specifically: 1. A "senior foreign political figure" is a senior official in the executive, legislative, administrative, military or judicial branches of a foreign government (whether elected or not), a senior official of a major foreign political party, or a senior executive of a foreign government owned corporation. In addition, a senior foreign political figure includes any corporation, business or other entity that has been formed by, or for the benefit of, a senior foreign political figure. 2. The "immediate family" of a senior foreign political figure typically includes the figure's parents, siblings, spouse, children and in-laws. 3. A "close associate' of a senior foreign political figure is a person who is widely and publicly known to maintain an unusually close relationship with the senior foreign political figure, and includes a person who is in a position to conduct substantial domestic and international financial transactions on behalf of the senior foreign political figure.

For Training Purposes Only

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