Introductory BSA/AML Examiner School, Atlanta, CA

BOARD RESOLUTION BANK OF SMITHVILLE SMITHVILLE, USA

The purpose of this Board Resolution (Resolution) is to set specific goals and time frames to address certain weaknesses noted in the Target Letter for the July 10, 20XX BSA review prepared jointly by the Federal Deposit Insurance Corporation (FDIC) and the State Bank Department (SBD). The Board of Directors, individually and collectively, agrees to ensure Senior Management of the Bank takes the corrective actions and uses their best efforts to accomplish the goals set forth in the following paragraphs. STAFFING 1. Within 60 days, Senior Management shall conduct a formal, independent staffing assessment of the BSA department, which should provide the basis for ensuring that sufficient personnel are devoted to the BSA/AML function. SUSPICIOUS ACTIVITY MONITORING 2. Within 60 days, Senior Management shall ensure that all Verafin alerts are reviewed in a timely manner and, if necessary, transferred to cases. The analysis of cases and submission of Suspicious Activity Reports (SARs) shall be performed within the time frames required by Part 353 of the FDIC Rules and Regulations. SUSPICIOUS ACTIVITY MONITORING 3. Within 90 days, Senior Management shall develop processes to detect, analyze, and document unusual transactional activity that is not detected or alerted by Verafin parameters or is outside of its capabilities. Additionally, all cashier’s checks outstanding for more than six months shall be reviewed for possible suspicious activity on a quarterly basis. HIGH-RISK CUSTOMERS 4. Within 90 days, Senior Management shall ensure that all ATM activity of customers operating privately-owned ATMs have separate accounts isolating only the ATM activity, to ensure proper monitoring for suspicious activity. Management shall also establish procedures that dictate an appropriate frequency for the review of all high-risk customers. VIOLATIONS 5. Within 60 days of the date of this Resolution, Senior Management shall, consistent with sound banking practices, ensure that all apparent violations cited in the Target Letter are corrected. Senior Management shall also adopt procedures to prevent recurrence of apparent violations.