BSA/AML Student Exercises Dec. 2022

Pay Upon Proper Identification Currently our Bank does not process any PUPID wire transfers to non-customers. Abbreviations and Addresses Although the Travel Rule does not permit the use of coded names or pseudonyms, the rule does allow the use of abbreviated names, names reflecting different accounts of a corporation (i.e., XYZ Payroll Account), and trade and assumed names of a business ("doing business as") or the names of unincorporated divisions or departments of the business. Customer Address The Travel Rule allows the use of physical mailing addresses only. Post office boxes can be used as an alternate address for mailing purposes, as long as the institution maintains the transmitter's physical address on file. Retrievability Rules Records related to these transactions must be maintained for five years. All Information retained by the Bank (originating bank) must be retrievable by reference to the name of the originator and account number. Intermediary banks have no retrievability rules under the amended rules. OFAC Compliance The customer identification program (CIP) procedures in the BSA now require the Bank to verify all new customers against the lists published by the Office of Foreign Assets Control (OFAC). It is against the law to do business with or for any person or entity on the list, and you can't know who that is unless you verify transactions. In today's BSA examination climate, it is likely that if you do not check all outgoing and incoming international wires, you might find the Bank under a regulatory enforcement order. The Best Practice is to verify each of the parties to each outgoing and incoming wire against the OFAC list. This means you check the name of your customer, his customer, and the ultimate beneficiary bank. For foreign wires, the beneficiary bank is not the correspondent bank through which you send the wire; it is the bank in the foreign country. Please refer to the OFAC Policy and Procedures. Funds transfer personnel should refer to the OFAC Policy and Procedures for access to lists of countries and entities with which the Bank may not do business and should refer to such lists whenever sending or Overview It is the policy of the Bank to ensure proper adherence to Section 314 of the USA PATRIOT Act, which authorizes the sharing of information between the federal government and financial institutions, and among financial institutions, for the purpose of identifying possible money laundering or terrorist activities. Section 314(a) Requests for Records — Information Sharing between Law Enforcement A Federal law enforcement agency investigating terrorist activity or money laundering may request that FinCEN solicit certain information from the Bank on the investigating agency's behalf. When submitting receiving foreign funds. Please refer to the OFAC Policy and Procedures. XVII. Information Sharing – USA PATRIOT Act Policy and Procedures

For Training Purposes Only

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