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					                                                                 Section:             Revised:       Number:
                           Standard Operating                        Financial          2/18/09      SOP 004-01 Rev B
                               Procedures                            Services

Subject:                                                                                             Page:
                              Anti-Money Laundering                                                          1 of 2

Scope:          All Accounting Department, Human Resources Department and all AAA Central Penn employees who
sell or handle American Express Travelers Cheques, Travelex foreign currency and CashPax and Meta Bank prepaid
VISA Travel Money Cards and VISA Gift Cards and Western Union.

Purpose:       To ensure compliance with all Anti-Money Laundering laws regulating Money Services Businesses like
AAA Central Penn.

References:    Anti-Money Laundering Manual

Procedure:

1.     All Accounting Department, Human Resources Department and all AAA Central Penn employees who will train,
       sell or handle, or are currently training, selling or handling Travelex financial products must:
              Undergo initial Anti-Money Laundering Training prior to handling or selling AAA offered financial products
              Review the Anti-Money Laundering Manual and any other training materials provided on this subject at
               least every six months in order to keep this information fresh and top-of-mind (more frequent review is
               encouraged).
              Repeat Anti-Money Laundering Training whenever significant revisions are made in program materials,
               (e.g., regulation changes, procedural changes, etc.), or as a refresher at the Compliance Officer’s
               discretion.
              Sign the Anti-Money Laundering Log to acknowledge any formalized training that has been provided, and
               to affirm that they have read and understood the AAA Central Penn Anti-Money Laundering Manual.

2.     Anti-Money Laundering Training must include understanding of the following key points:
              The definition of Money Laundering
              The Money Laundering process, and its three basic steps
              The most common methods used to launder money
              Each employee’s legal responsibilities and potential penalties for non-compliance
              U.S. Anti-Money Laundering laws.
              The definition of a Money Services Business (MSB).
              How to record customer identification for each type of transaction covered under these regulations.
              When and how to file a Suspicious Activity Report (SAR).
              When and how to file a Currency Transaction Report (CTR-Form 104).
              Familiarization with OFAC (Office of Foreign Assets Control) requirements.

3.     The Anti-Money Laundering Compliance Officer is Tim Hanford.
              The Compliance Officer is responsible for implementation and oversight of the Anti-Money Laundering
               Compliance Program, including staff training and ensuring that all regulatory requirements are being met.
              Contact the Compliance Officer for questions about the Compliance Program.
              Forward all Suspicious Activity Reports to the Compliance Officer immediately upon completion.
              The Compliance Officer will file all Suspicious Activity Reports with appropriate authorities.
              Forward all Currency Transaction Reports to the Compliance Officer immediately upon completion.
              The Compliance Officer will file all Currency Transaction Reports with appropriate authorities.




Approved By:                                                Effective Date:
                     Tim Hanford                                                 February 18, 2009
                                                                 Section:             Revised:       Number:
                           Standard Operating                        Financial          2/18/09      SOP 004-01 Rev B
                               Procedures                            Services

Subject:                                                                                             Page:
                              Anti-Money Laundering                                                          2 of 2




4.    Customer Service Guidelines:
           It is important to remember that a high level of quality customer service must be maintained while
               administering the AAA Central Penn Anti-Money Laundering Compliance Program.
           Focus on unusual activity.
           Avoid quizzing/interrogating members and customers (particularly those who transact frequent business
               with the club, and are well known by the staff).
           Remember that money launderers prefer cash transactions.
           When in doubt about any transaction, fill out a Suspicious Activity Report, forward it to the Compliance
               Officer and leave the rest to law enforcement (do NOT inform the member/customer that a report is or
               will be prepared).

5.    OFAC (Office of Foreign Assets Control) List
              The Compliance Officer will ensure that the club’s list of members is periodically compared to the current
               OFAC list, using the Campana reporting system.
              Frontline staff must familiarize themselves with the overall format of the OFAC list.
              In the event that a non-member makes a request for some suspicious transaction, (the suspicious nature
               of any given transaction is left to the discretion of the employee), the staff member being asked to
               perform the transaction must discreetly check the customer’s name against the on-line OFAC list (the
               website to be used is http://www.treas.gov/offices/enforcement/ofac/sdn/t11sdn.pdf, and should be
               added to “Favorites” on each computer used for this purpose).
              The Compliance Officer will keep a periodically updated hard copy of the OFAC list, in case of computer
               system or Internet access failure.
               (a) If a suspicious transaction is requested during a period of computer system or Internet access
                    failure, contact the Compliance Officer.




Approved By:                                                Effective Date:
                     Tim Hanford                                                 February 18, 2009

				
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