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BSA/AML Questionnaire

This form should be completed by the individual responsible for Bank Secrecy Act (BSA) and Anti-Money Laundering (AML) compliance at your institution. We appreciate your cooperation in assisting us with our compliance efforts. If you have any questions, please contact Joanie Hale at jhale@tbb.bank.

BSA/AML Questionnaire

Please complete all questions and related requests for information.

1. Has your institution had any regulatory or criminal enforcement actions resulting from violations of BSA/AML laws or regulations in the last five years?
Yes
No
2. Does your institution perform a periodic risk assessment focused on its customer base, products/services, and geography?
Yes
No
3. Has your institution developed procedures to address risks identified in the risk assessment?
Yes
No
4. Does your institution's program include policies, procedures, and controls that address regulatory requirements and guidance that apply to your institution?
Yes
No

5. Does your institution offer products/services to the following? (Definitions at bottom of page.)

Cannabis Related Businesses
Yes
No
Cash Intensive Businesses
Yes
No
Casinos
Yes
No
Companies whose ownership is evidenced by bearer shares
Yes
No
Companies of Privately Owned ATMs
Yes
No
Digital Assets
Yes
No
Domestic Non-Bank Financial Institutions
Yes
No
Embassies and Foreign Consulates
Yes
No
Exchange Houses
Yes
No
Foreign Businesses
Yes
No
Foreign Financial Institutions
Yes
No
Foreign Nongovernmental Organizations and Charities
Yes
No
Internet Banks
Yes
No
Internet Gambling Companies
Yes
No
Money Services Businesses
Yes
No
Nonresident Aliens and Foreign Individuals
Yes
No
Offshore Banking Units
Yes
No
Politically Exposed Persons
Yes
No
Third-Party Payment Processors
Yes
No
Trading Companies
Yes
No
6. Has your institution identified as high risk any customer types not listed above?
Yes
No
7. If you answered "Yes" to any item above, do policies, procedures, monitoring, and programs address how to mitigate risks associated with these higher-risk customer types?
Yes
No
8. Has your institution chosen to prohibit specific customer types?
Yes
No
9. Does your institution risk rate customer, products/services, and geographies?
Yes
No
11. Does your institution prohibit opening of anonymous accounts?
Yes
No
12. Does your institution conduct any banking transactions with non-account holders?
Yes
No
13. Does your institution monitor for unusual and suspicious activity that covers cash deposits and withdrawals, funds transfers, and sale of monetary instruments such as travelers' checks and money orders?
Yes
No
14. Does your institution monitor for unusual activities based on expected account activities?
Yes
No
15. Is sanctions screening conducted during on-boarding, periodic review, and on transactions going through your institution?
Yes
No
16. How frequently is independent audit or testing conducted of your institution's BSA/AML/Anti-Terrorist Financing (ATF) compliance program?
Monthly
Quarterly
Annually
Other

Signature

I certify that, to the best of my knowledge, the above information is current, accurate and reflective of my institution's BSA/AML/ATF policies, procedures, and practices and that I will update The Bankers Bank with any material changes to the answers above in a timely manner.

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Date
Month
Day
Year

Definitions:


Bearer Shares – Corporation stock certificates that allow ownership of the corporation to be conveyed by simply transferring physical possession of the shares. 


Cannabis Related Businesses – Those businesses involved in the growing, manufacturing, distribution, sale, or ownership of marijuana or marijuana-related consumables.


Internet Bank – Bank operating solely on the Internet, without any physical premises.


Internet Gambling or Gaming Companies – A business or organization that places, receives, or knowingly transmits bets or wages by any means which involves the use, at least in part, of the Internet.


Money Service Business – An entity doing business in one or more of the capacities listed below.

  • Dealer in foreign exchange

  • Check casher

  • Issuer or seller of traveler's checks or money orders

  • Provider of prepaid access

  • Money transmitter

  • U.S. Postal Service

  • Seller of prepaid access


Ownership – “Beneficial or true owner” of an account is an individual who has a level of control over, or entitlement to, the funds or assets in the account that, as a practical matter, enables the individual, directly or indirectly, to control, manage, or direct the account. This includes both owners who own directly and those that own indirectly through other entities or individuals.


Offshore Banking Unit – A bank with a license to conduct banking activities that, as a condition of the license, prohibits the licensed entity from conducting banking activities with the citizens, or in the local currency of, the jurisdiction that issued the license.


Politically Exposed Person (PEP) – Senior foreign political figures and their immediate family members and close associates.


Professional Service Provider – Acts as an intermediary between its client(s) and the bank.


Trading Companies – Companies organized to carry on commerce with foreign nations or in overseas territories.

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