Introductory BSA/AML Examiner School, Atlanta, CA

Lawful Internet gambling businesses will be required to provide extensive documentation at account opening. Marijuana-Related Businesses Anytown Community Bank do not provide financial services to these types of account relationships. Procedures are in place to prevent marijuana related businesses from opening or maintaining an account. If at a future date, management deems it advisable to offer marijuana-related businesses financial services the consent of the Board of Trustees/Managers will be obtained, and management will establish enhanced due diligence procedures including suspicious activity reports filings. POLICY ELEMENTS Authority and Responsibility The Board of Trustees/Managers will receive an initial briefing regarding the requirements of the final CIP regulations. Thereafter, the Board will review, discuss, and if accepted, adopt the formal CIP program as a sub-policy of the Bank’s BSA/AML and OFAC Policies. The CIP sub-policy will be reviewed annually. It will also be considered in support of the overall BSA/AML/OFAC compliance policy efforts on an annual basis. The Board has previously designated the Compliance Officer as the BSA Officer who is responsible for overseeing Anytown Community Bank’s BSA compliance program. Accordingly, the BSA Officer or his/her designee will coordinate and direct the development, implementation and ongoing monitoring of the Bank’s day-to-day compliance with BSA and CIP requirements. In carrying out these responsibilities, the BSA Officer and/or his/her designee will: • Perform an institution-wide survey and risk assessment of procedures for obtaining and verifying customer identity information utilized by all departments where a customer account relationship may be established. • Review existing policies and procedures for customer identification in relation to the requirements of CIP. • Develop, implement, and maintain risk-based customer identification procedures and controls which include: o Obtaining and verifying the identity information of any person seeking to open an account, including name, address, and other identifying information, o Maintaining records of the information used to verify the person’s identity, and o Determining whether the person appears on any government lists • Implement staff training programs. • Receive periodic training to maintain proficiency in AML requirements. • Monitor the continuing effectiveness of the CIP and recommend any program changes to the Board for review and approval. • Provide for periodic independent testing and audit review of the program. Risk Assessment and Management The BSA Officer is charged with the responsibility for ensuring that an institution-wide risk assessment is initially conducted to determine the risks associated with the Bank being unable to properly identify persons seeking to open new accounts, and therefore being unable to form a “reasonable belief” that it knows the true identities of its customers. The risk assessment will result in the establishment of risk- based procedures appropriate to different account opening situations. Factors relevant to this risk assessment will include: size of the bank; location of the bank; type of business and customer base; types of accounts offered by the bank; various methods of opening accounts; and types of identifying information available.