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EFTA01372648
eview of PCR and RDC alerts (if any) and the decisioning around escalation processes as defined within DBUS policy. As part of the File Review, the AML Unit will take into consideration DBUS AML policy, Global Banking New Client Adoption Process procedures, applicable USA PATRIOT Act provisions (Section
EFTA01372646
The AML Unit will evidence/document each file reviewed by utilizing the attached TALF Borrower File Review Assessment Form. e x 1 TALF File Assessment. xls S
EFTA01372647
tative review of PCR alerts (if any) and the decisioning around escalation processes as defined within DBUS policy. As part of the File Review, the AML Unit will take into consideration DBUS AML policy, CRE procedures, applicable USA PATRIOT Act provisions (Section 326) as well as regulations and guidanc