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It states the Company’s policy to comply with applicable anti-money laundering laws and U.S. economic and trade sanctions regulations, supported by a USA PATRIOT Act-based AML program, a director-led compliance organization, written policies and internal controls, customer identification and due diligence processes, employee training, suspicious activity monitoring and reporting, and independent auditing. 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It is the policy of SunTrust Banks, Inc. and its subsidiaries, including SunTrust Bank, a Georgia banking corporation and member bank of the Federal Reserve System (collectively, the “Company”) to comply with all applicable federal laws and regulations governing anti-money laundering and U.S. economic and trade sanctions. The Company is regulated by the Board of Governors of the Federal Reserve System, the Georgia Department of Banking and Finance, and several other U.S. regulatory entities with jurisdiction over the Company’s activities.  \nThe Company is required to, and maintains, an anti-money laundering program pursuant to the requirements of the USA PATRIOT Act and regulations promulgated thereunder (the “AML Program”) . The Company has appointed a Director of AML Compliance who leads a compliance organization of employees with experience in this field, which oversees the AML Program. The AML Program includes written policies and procedures designed to prevent money laundering; and specifically, internal controls for ongoing compliance, a customer identification program under Section 326 of the USA PATRIOT Act; customer due diligence and risk assessment procedures; ongoing anti-money laundering training for all employees; monitoring for, and reporting of, suspicious activity; and independent auditing to test the implementation of the Program. The Company does not transact with “shell banks”.  \nThe Company maintains a risk-based economic and trade sanctions compliance program designed to comply with sanctions programs administered and enforced by the U.S. Treasury’s Office of Foreign Assets Control (“OFAC”) . The Company has scanning systems and controls deployed on a risk-based approach, which it uses to scan customer and transaction data for comparison against the OFAC sanctions targets list, and reject or block transactions as required. The Company employs additional risk-based measures designed to prevent the Company from transacting or facilitating transactions that violate OFAC sanctions.  \nRevised December 30, 2016","cbCaiawa78tfnuJj","https://ap.wps.com/l/cbCaiawa78tfnuJj","pdf",307796,"English","# Anti-Money Laundering and Economic Sanctions Compliance Certification\n## Purpose and compliance scope\n## AML program requirements\n## Economic and trade sanctions program (OFAC)","[{\"question\":\"What is the purpose of the Anti-Money Laundering and Economic Sanctions Compliance Certification?\",\"answer\":\"It provides documentation for financial institutions requiring evidence of SunTrust Banks, Inc. and its subsidiaries’ compliance with anti-money laundering and economic and trade sanctions laws and regulations.\"},{\"question\":\"What elements are included in SunTrust’s anti-money laundering (AML) program?\",\"answer\":\"The certification describes written policies and procedures, internal controls, a customer identification program under Section 326 of the USA PATRIOT Act, customer due diligence and risk assessment, ongoing employee training, monitoring and reporting of suspicious activity, and independent auditing.\"},{\"question\":\"How does the Company handle economic and trade sanctions compliance with OFAC?\",\"answer\":\"It maintains a risk-based sanctions compliance program using scanning systems to compare customer and transaction data against OFAC targets, and to reject or block transactions as required, supported by additional risk-based measures to prevent prohibited facilitation.\"}]","Anti-Money Laundering and Economic Sanctions Compliance Certification | PDF",1789132916]