Bank Secrecy Act/Anti-Money Laundering Policy

Subsequent to September 11, 2001, the U.S. government enacted the USA PATRIOT Act to deter and punish terrorist acts in the U.S. and around the world. A key provision of this legislation requires the financial services industry to implement an anti-money laundering (AML) program. Nevertheless, money laundering is not a new phenomenon or a new risk for financial institutions, as Congress passed the Bank Secrecy Act (BSA) in 1970 in an effort to prevent banks from being used to hide money derived from criminal activity.

IDB Bank has committed substantial resources to create a robust, compliance program and to enhance our existing policies and procedures. As required by the USA PATRIOT Act and other legislation, our compliance program includes a designated BSA/AML Compliance Officer, focused employee training, and independent audits to test the program. These internal controls will assist IDB Bank in detecting and reporting suspicious transactions to the government.

The regulations require us to know our clients. IDB Bank is dedicated to providing our clients with first-rate, quality service and exceptional, personalized attention. In line with this, we may ask clients for additional information and documentation about certain accounts and transactions from time to time.

We will continue to enhance our internal controls and processes to keep current with the latest rules and regulations. IDB Bank's customers can take added comfort in conducting their business with us.