text: • 
  to conduct enhanced scrutiny of account relationships to guard against money laundering and report any 
  suspicious transaction; 
  
  • 
  to ascertain the identity of the nominal and beneficial owners of, and the source of funds deposited into, 
  each account as needed to guard against money laundering and report any suspicious transactions; 
  
  • 
  to ascertain for any foreign bank, the shares of which are not publicly traded, the identity of the owners of 
  the foreign bank, and the nature and extent of the ownership interest of each such owner; and 
  
  • 
  to ascertain whether any foreign bank provides correspondent accounts to other foreign banks and, if so, the 
  identity of those foreign banks and related due diligence information. 
  
  Under the USA PATRIOT Act, financial institutions are also required to establish anti-money laundering 
  programs. The USA PATRIOT Act sets forth minimum standards for these programs, including: 
  
  •  the development of internal policies, procedures, and controls; 
  
  •  the designation of a compliance officer; 
  
  •  an ongoing employee training program; and 
  
  •  an independent audit function to test the programs. 
  
  In addition, the USA PATRIOT Act also requires the Secretary of the Treasury to adopt rules addressing a 
  number of related issues, including increasing the cooperation and information sharing between financial 
  institutions, regulators, and law enforcement authorities regarding individuals, entities and organizations engaged in, 
  or reasonably suspected based on credible evidence of engaging in, terrorist acts or money laundering activities. Any 
  financial institution complying with these rules will not be deemed to violate the privacy provisions of the Gramm- 
  Leach-Bliley Act that are discussed below. Finally, under the regulations of the Office of Foreign Asset Control, we 
  are required to monitor and block transactions with certain “specially designated nationals” who OFAC has 
  determined pose a risk to U.S. national security. 