EFTA Document EFTA01356872

Classification: For Internal use only All, As you may know, per the AML Procedures manual, certain clients are excluded from ACUs. An issue has been identified in dbforce where High Risk clients are given an ACU Auto Exemption for Retail Banking, however, per Policy, this exception does NOT apply to High Risk clients. Unfortunately, the code in dbforce is exempting high risk clients with only deposit accounts under $250K from the ACU when it should not be-the code will be fixed, but in the