Introductory BSA/AML Examiner School, Atlanta, CA

• Section 312 – Requires special due diligence for certain foreign correspondent accounts and private banking accounts. • Section 313 – Prohibits United States correspondent accounts with foreign “shell banks” that do not have a physical presence in any country. At the present time, Anytown Community Bank does not engage in these types of account relationships with these foreign customers. If at a future date management deems it advisable to offer any of these types of account relationships legally permitted under law, the consent of the Board of Trustees will be obtained, and management will establish special due diligence procedures and controls as required by the applicable section(s) of the USA PATRIOT Act and implementing regulations. New account procedures and systems are in place to monitor for these types of relationships with particular attention to the funds transfer area. CERTIFICATION OF ADOPTION This is to certify that the preceding Customer Identification Program Policy was adopted at the Board of Trustees meeting, which was duly noticed, legally constituted and held on the 16 th day of November, 2017. Certified this 16 th day of November, 2017 by: Jane L. Doe Secretary of the Board of Trustees Jane L. Doe

____________________________________ (Signature, Secretary of the Board of Trustees)