Common use of November 21, 2011 Clause in Contracts

November 21, 2011. “On a side note, although I understand from time to time we have to manage priorities, including systems security projects, I am very stretched and I am seriously concerned on how behind we are on BSA/AML. We currently have 32 open AML cases, pending 6 SARs to be filed, and a backlog of 42 AML cases involving cash activity of 20 are possible structuring. I have not been able to complete the implementation of Patriot Officer or start on the high-risk customers risk scoring methodology. I also need to develop the annual BSA training material All of these projects are on top of the day-to-day regular operations of my area. As the BSA Officer for the bank I want to do a good job but feel that staff and time being dedicated to BSA does not commensurate with the size and risk profile of the bank to ensure safe operations.” (Emphasis added.) 37. Despite BUSA’s BSA Officer’s repeated concerns and complaints, BUSA’s Chief Compliance Officer did not further increase staffing in the bank’s BSA department. In turn, the BSA Officer sent additional appeals for assistance to the Chief Compliance officer in in late 2011: a. December 5, 2011: There is no doubt that I also want to move forward and ensure that all outstanding compliance concerns are resolved but my hands are also tied with staffing contains [sic].5 I am going to sound like a broken record but I am busy this week and next week providing BSA training. I have 23 open AML cases plus 6 new SARs to file I have not been able to move forward with implementation of Patriot Officer due to all the systems security issues. [BSA Employee #3] is the day-to-day system security fires and BSA operations plus a back log of 40 AML cases.” (Emphasis added.)

November 21, 2011. “On a side note, although I understand from time to time we have to manage priorities, including systems security projects, I am very stretched and I am seriously concerned on how behind we are on BSA/AML. We currently have 32 open AML cases, pending 6 SARs to be filed, and a backlog of 42 AML cases involving cash activity of 20 are possible structuring. I have not been able to complete the implementation of Patriot Officer or start on the high-risk customers risk scoring methodology. I also need to develop the annual BSA training material All of these projects are on top of the day-to-day regular operations of my area. As the BSA Officer for the bank I want to do a good job but feel that staff and time being dedicated to BSA does not commensurate with the size and risk profile of the bank to ensure safe operations.” (Emphasis added.) 37. Despite BUSA’s XXXX’x BSA Officer’s repeated concerns and complaints, BUSA’s XXXX’x Chief Compliance Officer did not further increase staffing in the bank’s BSA department. In turn, the BSA Officer sent additional appeals for assistance to the Chief Compliance officer in in late 2011: a. December 5, 2011: There is no doubt that I also want to move forward and ensure that all outstanding compliance concerns are resolved but my hands are also tied with staffing contains [sic].5 I am going to sound like a broken record but I am busy this week and next week providing BSA training. I have 23 open AML cases plus 6 new SARs to file I have not been able to move forward with implementation of Patriot Officer due to all the systems security issues. [BSA Employee #3] is the day-to-day system security fires and BSA operations plus a back log of 40 AML cases.” (Emphasis added.)