EFTA Document EFTA01413503

AML Committee PWM AML Surveillance Status Report November and December 2013 MANAGEMENT SUMMARY Regulatory/Audit Fed Exam AML Compliance submitted response and remediation plan. 12-month review of CTRs and 345 Branch Operations Risk Assessment was completed in August 2013, and submitted to management on 9/4/2013. Internal audit of the Prime BSA and NetX Actimize PCS systems completed in early December 2013. Projects/Work Efforts 2012/2013 Prime BSA Upgrade Project goal is to upgrade