BSA/AML Student Exercises Dec. 2022

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) • Amount of payment order • Date of payment order • Payment instructions received from the originator (our customer) with the payment order • Identity of beneficiary's bank — the bank where the beneficiary has the account Name of beneficiary • Address of beneficiary • Account number of beneficiary • Other specific identifiers of beneficiary Additional Records for Non-Established Customers Currently, the Bank does not process any wire transfers to non-customers. Travel Rule Requirement for Outgoing Wires

For Training Purposes Only

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