Anti-money laundering policy

BannerWest does not tolerate money laundering and supports the fight against money launderers. BannerWest follows the guidelines set by the European Joint Steering Group on Anti-Money Laundering and is a full member of the Financial Action Task Force (FATF), an intergovernmental body that aims to combat money laundering and the financing of terrorism. BannerWest now has a policy to keep people from laundering money. This policy includes:

• ensuring that the customer has been authenticated

• recording any identification information

• determining that clients are not known or suspected terrorists by checking their names against known or suspected terrorists

• informing clients that information they provide can be used to verify their identity

• Detailed tracking of customer transactions

• Rejection of cash, money transfers, third party transactions, money transfers at exchange offices or Western Union transfers. Money laundering occurs when funds from illegal / criminal activities move through the financial system in a way that gives the impression that the funds came from legitimate sources.

Money laundering usually takes place in three stages:

• first, cash or cash equivalents are placed in the financial system

• second, money is transferred or moved to other accounts through a series of financial transactions designed to hide the origin of money (for example, making transactions with little or no financial risk or transferring account balances to other accounts)

• second, money is transferred or moved to other accounts through a series of financial transactions designed to hide the origin of money (for example, making transactions with little or no financial risk or transferring account balances to other accounts)

Personal accounts in our system are one of the means that can be used to launder illegal funds or to conceal the true owner of the funds. In particular, a trading account can be used to carry out financial transactions that help obscure the origin of funds. As a preventative measure, BannerWest directs withdrawals back to the original source of the money transfers. The International Money Laundering Service requires financial institutions to be aware of potential money laundering abuse that may be taking place in a customer's account and to implement a compliance program to detect, detect and report possible suspicious activity. These guidelines have been implemented to protect BannerWest and its customers. For questions / comments regarding these guidelines, please contact us at info@bannerwest.com.

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