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Compliance Guidelines February 17 th 2014

VENTURE Credit Union. Compliance Guidelines February 17 th 2014. Our Objective. The best of both worlds. Complying with the FIU and FATCA. Excellent Member Service. Sustainable & Profitable VCU. Compliance –Step 1 (a)- Know your Member. Step 1 (a) – Know Your Member.

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Compliance Guidelines February 17 th 2014

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  1. VENTURE Credit Union Compliance GuidelinesFebruary 17th 2014

  2. Our Objective • The best of both worlds Complying with the FIU and FATCA Excellent Member Service Sustainable & Profitable VCU

  3. Compliance –Step 1 (a)- Know your Member Step 1 (a) – Know Your Member Member Application Form Verification of Income Additional Information Form Verification of address Source of Funds Verification of IDs

  4. Compliance Step 1 (b)- Know your Company • Step 1 (b) Know Your Company • Sole Traders/Partnerships • - Cert of Registration • - Copy of IDs • - Proof of Address for Owner or Company • Recent Financials • Source of Funds • Limited Liab. • Directors IDs • Certificate of Incorporation • Recent Annual Return Bye Laws • Resolution letter • Recent Financials • Source of Funds

  5. Compliance Step 2- Ask yourself • Step 2 ASK yourself: Is there anything about this transaction that made me suspicious? -Remember, the member should never ever be tipped off in any way. We do business with them as we ordinarily would once it is in accordance with our internal policies. -The member should never ever be made to feel like a suspect or criminal. -While we want to do our part to help combat Money Laundering and the Financing of Terrorism, our overarching Company Policy will always be to provide excellent service to members/potential members

  6. What makes you Suspicious? Examples • Sudden large deposits, repayments or withdrawals • Transfer of funds from high risk areas • Unusual Borrowing Activity • Deliberately providing none or insufficient data for SOF, or staying just below the limit

  7. What makes you Suspicious? Examples • Deliberate efforts to avoid record keeping (for companies) • Activities that are inconsistent with Members’ Line of Business • Shell/Paper Companies • Persons constantly doing business on behalf of a PEP or embassy official

  8. What makes you Suspicious? Examples • Unwilling to provide information required • Nervous/Shady behaviour • ANY other situation that made you feel suspicious or uncomfortable

  9. Compliance Step 3- Report to the Compliance Officer The following should be reported to the Compliance Officer:- 1) ALL suspicious transactions • These should be communicated over the phone or in person. • The Compliance officer will do the SAR/STR for the FIU. 2) ALL PEPs 3) ALL Foreign Citizens or Residents 4) ALL members with known illegal businesses eg. PH Taxi drivers, scalpers

  10. What happens… • If you did your due diligence, know your member and were NOT suspicious? -Move on with the rest of your life • If you reported someone to the Compliance Officer out of suspicion but that person is actually innocent? -Nothing, move on with the rest of your life

  11. Recap At ALL times, we maintain a friendly, helpful, member-oriented attitude “ The more successful you and your organization become, the more humble and devoted to your customers you need to be”-Robin Sharma Report to the Compliance Officer where applicable within 5 days Get to know your Member/ Company As yourself if you were suspicious

  12. Your Compliance One Pager

  13. Questions • Do you understand the 3 Steps of Compliance? • Do you know what to do when there is a suspicious activity? • Do you understand the new forms? • Do you understand the new procedures? (eg. “original seen”, proper address verification, putting your initials after requirements etc.) • When does all of this become effective?

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