Trust Examiner School eBook

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63. Training documentation (e.g., materials used for training since the prior State examination): the training schedule with dates, attendees, and topics. If training is web-based where training material cannot be downloaded, please send a list of required training.

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64. A biographical sketch or resume of the auditors that performed the BSA/AML and OFAC audit. Please make available BSA/AML auditor workpapers for examiner review.

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65. Records of funds transfers, for the most recent month, including incoming, intermediary, and outgoing transfers of $3,000 or more.

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66. A list of the following potentially “high-risk” accounts with the total account balance:

 Non-Governmental Organizations (Charity, Foundations, Endowments)  Politically Exposed Person

 Accounts without any taxpayer identification numbers such as Non-Resident Aliens  Accountholders domiciled outside the United States, including those with U.S. power of attorney

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67. A copy of any investigation logs and provide access to Suspicious Activity Reports (SARs) filed since the prior examination and the supporting documentation. Include copies of any filed SARs that were related to section 314(a) requests for information or to section 314(b) information sharing requests. Also make available any analyses or documentation of any activity for which a SAR was considered but not filed, or for which the bank is actively considering filing a SAR since the prior examination.

[Type Management Response Here]

68. If applicable, a copy of any processes for complying with 31 CFR Chapter X 1010.520 (Information Sharing Between Federal Law Enforcement Agencies and Financial Institutions). If applicable, please make available a copy of the most recent notification form to voluntarily share information with other financial institutions under 31 CFR Chapter X 1010.540 (Voluntary Information Sharing Among Financial Institutions), or a copy of the most recent correspondence received from FinCEN that acknowledges FinCEN's receipt of notice to voluntarily share information with other financial institutions.