Compliance Program Overview
The USA PATRIOT Act, Public Law 107-56, signed into law by President Bush October, 2001, enhances the anti-money laundering compliance requirements for banks and other financial institutions.
In accordance with Title III of the USA PATRIOT Act, and applicable federal regulations, Marshall & Ilsley Corporation (“M&I”) has adopted policies, procedures and controls designed to provide for the continued administration of an anti-money laundering program reasonably considered to assure and monitor compliance with the record keeping and reporting requirements of the Bank Secrecy Act, as amended. The program, implemented in cooperation with the efforts of M&I affiliates, is reviewed and modified as necessary in response to applicable statutory and regulatory changes. Core features of the anti-money laundering compliance program implemented by M&I include the following:
- Board of Directors-approved anti-money laundering policy
- Designated Bank Secrecy Act and Anti-Money Laundering Compliance Officer
- Internal Policies and Procedures applicable throughout the Corporation designed to comply with all applicable statutory and regulatory requirements and FATF anti-money laundering standards
- Detailed Wire Transfer Request Procedures
- Suspicious Activity Monitoring and Reporting
- Customer Identification Program
- Employee Training Program
- Independent Audit Review
- Reporting of Large Currency Transactions
- Office of Foreign Assets Control (OFAC) Monitoring
- Compliance with Record Retention Requirements
- Prohibition on Correspondent Accounts with Foreign Shell Banks
- Cooperation and Information Sharing with Law Enforcement
- Regulated Affiliate Certification Program for Offshore Branches
Marshall & Ilsley Corporation is publicly traded on the New York Stock Exchange (NYSE) under the symbol "MI", and is subject to regulation by the U.S. Securities and Exchange Commission. M&I is also a financial holding company (FHC) and is regulated in that capacity by the Federal Reserve Board of Governors.
Marshall & Ilsley Corporation is committed to complying with applicable laws and regulations targeted at assisting United States authorities in combating money laundering, terrorist financing, and other financial crimes. Additional questions can be directed to Peter Janczak, Vice President and Director of Corporate Compliance, M&I Bank Secrecy Act and Anti-Money Laundering Compliance Officer, at (414) 765-7856.
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