United takes reasonable and appropriate steps to prevent persons engaged in money laundering, fraud or other financial crime from utilizing United’s products and services to facilitate criminal activity. We have implemented an enterprise-wide Anti-Money Laundering (AML) and Combating the Financing of Terrorism (CFT) compliance program, which is applicable to all employees, subsidiaries and affiliates. The program provides guidance through Board-approved corporate policies, written procedures and established controls designed to identify and appropriately mitigate money laundering risks. The program includes, but is not limited to, customer due diligence and account documentation requirements, identification of higher risk customers through expanded due diligence questions, reporting of large currency transactions and monitoring customer transactions for suspicious activity.
The Board’s expectations for adherence to all AML/CFT laws, rules and regulations is clearly communicated to all employees. Annual training is mandatory and participation tracked at all levels, including management and the Board. The Chief Compliance Officer apprises the Risk Committee of AML/CFT matters on a quarterly basis. United’s AML/CFT risk level and program effectiveness is evaluated through an annual risk assessment, periodic independent third party audit and annual regulatory examinations.
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