A. Compliance Department

1. Background check (integrity Due Diligent) an area the compliance function is

responsible for the risk-based system for background checks of business partner.

The examination and assessment of business partners, including ownership and key

personal (such as director and officer), in order to obtain reasonable assurance of their

integrity and business ethic.

2. Risk based approach.

3. AML/CTF bank staff trainings.

4. Write formal letter or report to NBC or FIU if necessary.

5. Other tasks assigned by Head of Department.

B. Name Screening

1. World Check One System

- Support operation and loan department for screening new or existing customer.

- Key customer profile data into world check system.

- Export the result back to operation and loan department.

2. Ongoing Monitoring on World Check One System (screening and risk rating).

3. Third party services screenings.

C. Review on Customer Risk Profile

1. KYC on customer profile.

2. Customer Due Diligent (KYC).

3. Enhancement Due Diligent.

4. High Risk Customer.

5. Politically Exposed Person (PEPs).

6. Risk Customer Profile.

7. Ongoing monitoring on Risk profile includes High risk, PEPs.

8. Non-Face to Face customers.

9. Remittance/Wire transfer.

10. Non-government organization and foundation.

11. Private Banking.

D. Reporting

1. Cash Transaction Report (CTR)

- Collect cash transaction from operation team for evaluated data.

- Key data into cash transaction report Platform.

- Submit cash transaction report into RBS system.

2. Suspicious Transaction Report (STR)

- Review and investigate suspicious transaction which is provided by operation team.

- Collect supporting and relevant documents for the suspicious activities.

- Key data into suspicious transaction report Platform.

- Submit suspicious transaction report into RBS system.

3. Quarterly report FATCA to IRS and Tax Department.

4. Quarterly report of Risk- based approach to NBC.

5. Keep and file CTR and STR, monthly report to Head of Department.

6. Upload report in RBS system.