BSA AML OFAC Policy

This policy is to document the Bank’s BSA/AML program to include:

• THE BANK SECRECY ACT OVERVIEW
• DESIGNATION OF THE BSA/AML OFFICER
• INTERNAL CONTROLS
• INDEPENDENT TESTING
• TRAINING
• RISK ASSESSMENT
• BSA REPORTING REQUIREMENTS
• MONEY LAUNDERING and OTHER PROHIBITED ACTIVITIES
• RECORDKEEPING and RETENTION
• CUSTOMER IDENTIFICATION PROGRAM
• UNUSUAL OR SUSPICIOUS ACTIVITY AT ACCOUNT OPENING
• KNOW YOUR CUSTOMER (KYC/CDD/EDD)
• CUSTOMER DUE DILIGENCE and ENHANCED DUE DILIGENCE
• OFFICE OF FOREIGN ASSETS CONTROL (“OFAC”)
• RED FLAG INDICATORS OF POTENTIAL SUSPICIOUS ACTIVITY
• ACCEPTABLE FORMS OF DOCUMENTARY IDENTIFICATION FOR CIP PURPOSES
• INTERNAL SUSPICIOUS ACTIVITY REPORT FORM