Introductory BSA/AML Examiner School, Atlanta, CA

• The other financial institution enters into a contract requiring it to certify annually to the bank that it has implemented its anti-money laundering program, and that it will perform the specified requirements of CIP. The Board also authorizes Senior Management, if it deems it advisable, to utilize the services of third- party vendors to support the bank’s CIP procedures by providing such functions as searches of public databases as an additional method of verifying customer identity, especially in situations where increased risk calls for these additional verification measures. The Bank may also utilize outside vendors and software systems providers to assist in the comparison of customer names with government lists. As always, these vendors will be subject to Bank oversight as deemed appropriate under the Information The CIP regulation requires a financial institution to provide adequate notice to customers that the bank will be requesting information to verify their identities. Such notice will be provided in such a manner reasonably designed to ensure that a customer is able to view the notice before opening an account. The Bank will provide this notice as follows: • Signs placed in Bank lobbies and in other areas where accounts are routinely opened. • Printed notices included on account applications. • On the bank’s Internet website where an application for a new account is available. Suspicious Activities Personnel must always be alert to situations which may lead to money laundering and other illegal activities. Potential abuses can occur with respect to deposit, wire transfer, and lending transactions. Staff must be familiar with the types of situations that may be signs of money laundering activity. When suspicious activity is suspected or discovered, employees are expected to follow the procedures for bringing these activities to the attention of supervisors, and ultimately to the BSA Officer, as described in the Bank’s BSA procedures. Training Training should occur on a regular basis, both for new employees and experienced employees. Training should cover the basic rules of BSA, the Bank’s BSA/AML/CIP procedures, common money laundering plots, and periodic updates on new or revised BSA rules. Documentation will be retained on all training, including materials and attendees. The Bank Secrecy Act Officer, or his/her designee, is responsible for conducting such training. Audit, Independent Testing The Bank’s Internal Auditor will provide ongoing monitoring of the Bank’s level of compliance with CIP regulatory requirements. An independent review by the Bank’s Internal Auditor shall be conducted at least annually, and the results of all such reviews documented and reported to Senior Management, including the BSA Officer and the Board of Trustees, or appropriate committee of the Board. COMPLIANCE WITH OTHER SECTIONS OF THE USA PATRIOT ACT The USA PATRIOT Act of 2001 includes several other sections under Title III that may impact the operation of Anytown Community Bank or Northeast Home Loan. The following sections of the Act place controls and restrictions on certain types of account relationships with a financial institution: • Section 311 – Impacts banks that open payable-through or correspondent accounts for foreign jurisdictions or foreign financial institutions. Security Program. Customer Notice