Procedures for Monitoring Compliance with this Policy

A minimum of once a year, the institutions internal auditor or an independent third party will review the BSA Officer’s suspicious activity file. The auditor will ensure that all identified suspicious activity was reviewed and appropriately handled. The auditor will also use the Cash Transaction Monitor System to search for suspicious activity that the BSA Officer may have missed.

BSA Officer Training

The BSA Officer will be allowed to attend two (2) one-day training classes per year. He or she will get to choose the training. The BSA Officer will also be allowed to subscribe to a BSA newsletter service.

The AML / BSA compliance program must encompass the following minimum requirements:

• A system of internal controls ensuring ongoing compliance
• Independent BSA / AML compliance testing
• Designate an individual or individuals responsible for BSA compliance (BSA compliance officer) management
• Training for relevant personnel