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AML & KYC Policy

Anti-Money Laundering & Know Your Customer

Last Updated: February 1, 2026

1

Our Commitment

Tradition Capital Bank is committed to preventing money laundering, terrorist financing, and other financial crimes. We maintain a robust Anti-Money Laundering (AML) program and Know Your Customer (KYC) procedures in compliance with applicable laws and regulations, including the Bank Secrecy Act (BSA), USA PATRIOT Act, and international standards set by the Financial Action Task Force (FATF).

2

Know Your Customer (KYC)

Before you can use our services, we must verify your identity. Our KYC process includes:

Identity Verification

Collection and verification of government-issued identification documents such as passport, national ID, or driver's license.

Address Verification

Confirmation of your residential address through utility bills, bank statements, or official correspondence dated within three months.

Risk Assessment

Evaluation of customer risk profile based on occupation, source of funds, and expected transaction patterns.

Screening

Checks against sanctions lists, PEP (Politically Exposed Persons) databases, and adverse media.

3

Transaction Monitoring

We continuously monitor transactions to detect suspicious activity. Our monitoring includes:

Real-time Screening

All transactions are screened in real-time against compliance rules.

Pattern Analysis

Advanced analytics to detect unusual behavior and transaction patterns.

Velocity Checks

Monitoring transaction frequency and volume for anomalies.

Geographic Risk

Assessment of geographic risk factors for cross-border transactions.

4

Suspicious Activity Reporting

When we detect potentially suspicious activity, we are legally required to file Suspicious Activity Reports (SARs) with the Financial Crimes Enforcement Network (FinCEN). We cannot inform you if a SAR has been filed about your account. We may also be required to freeze or close accounts involved in suspicious activity.

5

Enhanced Due Diligence

For higher-risk customers, we apply Enhanced Due Diligence (EDD), which may include:

  • Additional documentation requirements
  • Source of funds verification
  • Purpose of account inquiry
  • Ongoing enhanced monitoring
  • Senior management approval

Higher-risk categories include Politically Exposed Persons (PEPs), customers from high-risk jurisdictions, and accounts with unusual transaction patterns.

6

Record Keeping

We maintain records of all customer identification information and transaction data for a minimum of five (5) years after the account is closed, as required by law. This includes copies of identification documents, account opening records, and transaction histories.

7

Your Obligations

As a Tradition Capital Bank customer, you agree to:

  • Provide accurate and complete information
  • Update your information when it changes
  • Not use our services for illegal purposes
  • Cooperate with our verification requests
  • Report any suspicious activity you observe

Contact Our Compliance Team

If you have questions about our AML/KYC procedures or need to report suspicious activity, please contact our Compliance Department.