Anti-Money Laundering (AML) Policy

Anti-Money Laundering Policy Statement. This institution is committed to full compliance with all applicable anti-money laundering (AML) laws and regulations, including but not limited to the Bank Secrecy Act (BSA), the USA PATRIOT Act, and all regulations promulgated by the Financial Crimes Enforcement Network (FinCEN). This institution shall establish and maintain an effective AML compliance program that includes: (a) the designation of a qualified BSA/AML Compliance Officer responsible for the day-to-day oversight of the compliance program; (b) the development and implementation of internal policies, procedures, and controls designed to detect and report suspicious activity; (c) ongoing, risk-based employee training at all levels of the organization; (d) independent testing of the AML program on a periodic basis; and (e) a risk-based Customer Identification Program (CIP) and Customer Due Diligence (CDD) process, including Enhanced Due Diligence (EDD) for higher-risk customers. All employees are required to report any known or suspected suspicious activity to the BSA/AML Compliance Officer immediately. Failure to comply with this policy may result in disciplinary action, up to and including termination of employment and referral for criminal prosecution.