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Fulton Financial Corporation (FFC) and its affiliates and subsidiaries have established complete Bank Secrecy Act /Anti-Money Laundering (BSA/AML) and anti-terrorist financing policies and procedures that have been adopted by FFC and each affiliate and subsidiaries board of directors. FFC does not maintain any foreign branches and all domestic branches and subsidiaries of FFC are required to meet the corporation's BSA/AML policies and procedures. The specific laws and/or regulations governing BSA/AML include the following: Regulation H, The USA Patriot Act, The US Department of the Treasury - Office of Foreign Asset Control and The US Department of Treasury - Financial Crimes Enforcement Network. It is the objective of FFC to prevent criminals from using the corporation's facilities, systems and services to conceal illegal activity. Reports containing Currency Transaction Suspect Analysis, Monetary Instrument Chronological Log, High Volume CTR Customer Report, and Customers with Increasing Cash Activity Report, Kiting Suspect List, Uncollected Funds Report and Significant Balance Fluctuation Report are reviewed. In addition, FFC will monitor the following functional areas for any suspected criminal activity: Commercial Lending, Consumer Lending, Credit Card Lending, Private Banking, Domestic Wire Transfer, International Department, Electronic Services and Internet Banking. FFC does not conduct business with shell banks or offer Payable Through Accounts. Disclosures are required containing complete sender and beneficiary information for international funds transfer. All employees of FFC receive annual intra-net based training on BSA/AML. In addition, employees receive comprehensive classroom training that is specific to their job duties and responsibilities. Records of training content and attendance are maintained for a minimum of 5 years. The board of directors is fully committed to an effective "Know Your Customer" program comprised of management oversight, establishment of internal systems and controls, segregation of duties and training. The elements of the program are communicated to all levels of personnel to insure a thorough understanding of individual responsibilities and the prompt identification of unusual activity to senior management. Records are maintained in accordance to record retention requirements set forth by said regulation. FFC and its affiliates and subsidiaries are regulated by the following federal regulatory agencies: The Federal Deposit Insurance Corporation, The Federal Reserve Bank of Philadelphia, The Federal Reserve Bank of Richmond, and The Office of the Controller of Currency. FFC has appointed the following corporate officer responsible for overseeing the BSA/Anti-Money Laundering program. Mr. David W. Miller Tel. 717-390-2272 SWIFT: FLBKUS33 |