Establish and maintain an Anti-Money Laundering (AML) program reasonably designed to assure and monitor compliance with the BSA and its implementing regulations.

• Internal Controls - AML.1.1

  Establish and maintain a system of internal controls; including policies; procedures; and processes; designed to ensure ongoing compliance with BSA requirements.

• Independent Testing - AML.1.2

  Provide for independent testing for compliance to be conducted by institution personnel or by an outside party.

• Designated BSA Compliance Officer - AML.1.3

  Designate an individual or individuals responsible for coordinating and monitoring day-to-day compliance with BSA (BSA Compliance Officer).

• Training - AML.1.4

  Provide training for appropriate personnel.

• Customer Due Diligence (CDD) - AML.1.5

  Implement appropriate risk-based procedures for conducting ongoing customer due diligence (CDD); including understanding the nature and purpose of customer relationships and conducting ongoing monitoring.

Implement a written Customer Identification Program (CIP) appropriate for the institution's size and type of business.

• Policy and Procedures - CIP.1.1

  Establish a written CIP that is incorporated into the institution's BSA/AML program and approved by the Board of Directors.

• Minimum Information - CIP.1.2

  Specify the identifying information that will be obtained from each customer prior to account opening.

• Verification Procedures - CIP.1.3

  Describe reasonable; risk-based procedures for verifying the identity of the customer within a reasonable time after the account is opened.

• Recordkeeping - CIP.1.4

  Describe procedures for making and maintaining a record of all information obtained under the CIP procedures.

• Comparison with Government Lists - CIP.1.5

  Describe procedures for determining whether the customer appears on any lists of known or suspected terrorists or terrorist organizations issued by any federal government agency and designated as such by Treasury in consultation with the federal functional regulators.

• Customer Notice - CIP.1.6

  Provide customers with adequate notice that the institution is requesting information to verify their identities.

• Reliance on Other Institutions - CIP.1.7

  Describe circumstances in which the institution will rely on the performance by another financial institution (including an affiliate) of any procedures of the institution's CIP.

Establish risk-based procedures for conducting customer due diligence; including understanding customer relationships; conducting ongoing monitoring; identifying beneficial owners; and implementing enhanced due diligence for high-risk customers.

• Understanding Customer Relationship - CDD.1.1

  Implement procedures for understanding the nature and purpose of customer relationships to develop a customer risk profile.

• Ongoing Monitoring - CDD.1.2

  Conduct ongoing monitoring to maintain and update customer information and to identify and report suspicious transactions.

• Beneficial Ownership Identification - CDD.1.3

  Establish procedures for identifying and verifying the identity of beneficial owners of legal entity customers; subject to certain exclusions and exemptions.

• Enhanced Due Diligence (EDD) - CDD.1.4

  Implement risk-based enhanced due diligence (EDD) procedures for customers identified as presenting a higher risk for money laundering or terrorist financing.

Implement systems and procedures for identifying; evaluating; and reporting suspicious activity.

• Identification and Detection - SAR.1.1

  Establish procedures for identifying and detecting potentially suspicious activity.

• Reporting Criteria - SAR.1.2

  Define clear criteria and thresholds for determining when a Suspicious Activity Report (SAR) must be filed.

• Filing Procedures - SAR.1.3

  Establish procedures for the timely and accurate completion and filing of SARs with FinCEN.

• Confidentiality - SAR.1.4

  Maintain the confidentiality of SARs and information that would reveal the existence of a SAR.

• Recordkeeping - SAR.1.5

  Maintain copies of filed SARs and the underlying supporting documentation.

Implement systems and procedures for identifying; aggregating; and reporting large currency transactions.

• Identification of Reportable Transactions - CTR.1.1

  Establish procedures to identify currency transactions exceeding $10;000 conducted by; or on behalf of; one person in one business day.

• Aggregation - CTR.1.2

  Implement procedures to aggregate multiple currency transactions conducted by or on behalf of the same person in a single business day.

• Filing Procedures - CTR.1.3

  Establish procedures for the timely and accurate completion and filing of FinCEN Currency Transaction Reports (FinCEN Form 104).

• Exemptions - CTR.1.4

  Establish procedures for granting; documenting; and monitoring CTR exemptions; if applicable.

• Recordkeeping - CTR.1.5

  Maintain copies of filed CTRs and related documentation.

Comply with various BSA recordkeeping requirements.

• Funds Transfer Recordkeeping - REC.1.1

  Maintain records for funds transfers (including wires) of $3;000 or more.

• Monetary Instrument Log - REC.1.2

  Maintain records related to the sale of certain monetary instruments (e.g.; cashier's checks; money orders; traveler's checks) for currency between $3;000 and $10;000; inclusive.

• CIP/CDD Records - REC.1.3

  Maintain records required under the institution's CIP and CDD procedures.

• Other Required Records - REC.1.4

  Maintain other records as required by the BSA and its implementing regulations.

Comply with BSA requirements regarding information sharing under Sections 314(a) and 314(b).

• Section 314(a) Procedures - INF.1.1

  Establish procedures for responding to FinCEN requests for information regarding accounts or transactions of named subjects (Section 314(a)).

• Section 314(b) Procedures - INF.1.2

  Establish procedures for voluntary information sharing with other participating financial institutions regarding suspected money laundering or terrorist financing (Section 314(b)); if the institution chooses to participate.

• Recordkeeping - INF.1.3

  Maintain records related to information sharing activities.

Comply with special measures imposed by FinCEN under Section 311 of the USA PATRIOT Act.

• Identification of Section 311 Actions - SPC.1.1

  Establish procedures to monitor FinCEN guidance and rulemakings for the imposition of special measures against foreign jurisdictions; financial institutions; classes of transactions; or types of accounts deemed to be of primary money laundering concern.

• Implementation of Measures - SPC.1.2

  Implement procedures to comply with the specific requirements of any imposed special measure.