Introductory BSA/AML Examiner School, Atlanta, CA

ANYTOWN COMMUNITYBANK

Policy for:

Customer Identification Program (CIP)

Board Approved:

November 16, 2017

Date Last Revised:

October 25, 2016

Individual Responsible For Maintaining/Updating Policy:

Bank Secrecy Act Officer

STATEMENT OF NEED AND DEFINITION The federal government requires that financial institutions assist in the criminal, tax, or regulatory investigation process of fighting drug sales, tax evasion, terrorist activities, and other criminal offenses. By carefully identifying individuals, businesses, and other entities at the time an account relationship is created, information can be carefully screened to prevent criminals from accessing the financial services system, to monitor subsequent account activities including large currency transactions, and to assist the government to focus on suspicious individuals who deposit or transfer large amounts of currency. THE PURPOSE The Board of Trustees of Anytown Community Bank understands the regulatory CIP requirements and, therefore, the necessity of carefully identifying persons and entities who establish new account relationships with the bank. Therefore, the Board has adopted this policy to comply with the Financial Record-Keeping and Reporting of Currency and Foreign Transactions Act/Bank Secrecy Act (BSA) and relevant Office of Foreign Assets Control (OFAC) requirements as well as other anti-money laundering (AML) requirements, including those implemented under the USA PATRIOT Act. The CIP requirements are an integral component to achieve compliance with the BSA, related OFAC requirements, and other AML elements. The CIP requirements are dictated by Section 326 of the USA PATRIOT Act, which subsequently amended the Bank Secrecy Act. The CIP objectives are specifically detailed in the regulation, requiring institutions to meet minimum requirements which include: • Verifying the identity of any person seeking to open an account, to the extent reasonable and practicable. • Maintaining records of the information used to verify the person’s identity. • Determining whether the person appears on any lists of known or suspected terrorists or terrorist organizations provided to the financial institution by any government agency. These general objectives require management and staff to implement adequate identification, documentation, verification, and record-keeping procedures to assure compliance with all statutes and regulations, and adherence to recognized safe and sound banking practices; decrease the likelihood the Bank will become a victim of illegal activities undertaken by a customer; protect the reputation and strategic position of the organization; and maintain the institution’s positive relationship with its customers. Unlawful Internet Gambling The purpose of this policy is also to prevent unlawful Internet gambling businesses from utilizing the banking system. Anytown Community Bank established this written policy and procedures to screen and prevent unlawful Internet gambling businesses (casinos and others) from opening an account at the Bank.