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# AML/KYC Policy

Texas Capital Bank
Contact Email: [email protected]

## 1. Introduction

Texas Capital Bank (“the Bank”) is committed to maintaining the highest standards of Anti-Money Laundering (AML), Counter-Terrorist Financing (CTF), and Know Your Customer (KYC) compliance.
This policy outlines the framework and procedures the Bank uses to prevent the misuse of its services for money laundering, terrorist financing, fraud, corruption, and other financial crimes.

## 2. Purpose of the Policy

The primary objectives of this AML/KYC Policy are to:

- Ensure compliance with global AML/CTF regulations and best practices.

- Protect the Bank, customers, and stakeholders from financial crime risks.

- Establish clear customer onboarding and verification processes.

- Define responsibilities for employees regarding AML/CTF prevention.

## 3. Legal & Regulatory Compliance

Texas Capital Bank adheres to international standards including:

- Financial Action Task Force (FATF) Recommendations

- Basel Committee Guidelines

- Wolfsberg Group Standards

- Applicable national and regional AML/CTF regulations

Compliance with these standards ensures the Bank maintains integrity and promotes transparency in all operations.

## 4. Customer Due Diligence (CDD)

The Bank performs Customer Due Diligence on all clients prior to establishing any business relationship.

### CDD Includes:

- Collecting and verifying identification documents

- Validating proof of address

- Verifying source of funds and source of wealth where applicable

- Conducting screening against global sanctions, PEPs, and watchlists

### When CDD is Applied:

- Opening accounts

- Processing large or unusual transactions

- Detecting suspicious behavior

- When doubts arise about previously collected information

## 5. Enhanced Due Diligence (EDD)

Enhanced Due Diligence is applied for higher-risk customers, including:

- Politically Exposed Persons (PEPs)

- High-risk jurisdictions

- Complex business structures

- Non-resident customers

- Unusual transaction patterns

EDD measures may include deeper verification, additional documentation, and continuous monitoring.

## 6. Ongoing Monitoring

Texas Capital Bank continuously monitors customer activity to detect and prevent suspicious transactions.

Key monitoring components include:

- Transaction pattern analysis

- Automated alerts for unusual activity

- Regular reviews of customer profiles

- Periodic risk assessments based on behavior and transaction history

## 7. Suspicious Activity Reporting (SAR)

Employees must promptly report:

- Suspicious transactions

- Unusual account activity

- Attempts to disguise source of funds

- Transactions inconsistent with the customer profile

All reports are handled confidentially and forwarded to the Bank’s AML Compliance Department for review and escalation to relevant authorities where required.

## 8. Risk-Based Approach (RBA)

Texas Capital Bank adopts a Risk-Based Approach to ensure AML/CTF controls are proportionate to the level of risk.

Risk factors evaluated include:

- Customer type

- Business activity

- Geographic exposure

- Transaction value and volume

- Delivery channels (online, in-person, third-party)

Actions are prioritized based on the assessed risk level.

## 9. Record Keeping

The Bank retains:

- Customer identification records

- Transaction histories

- CDD and EDD documentation

- Internal SAR reports

- Correspondence with regulatory authorities

Records are kept for at least five (5) to ten (10) years, depending on applicable regulations.

## 10. Employee Training

Texas Capital Bank ensures ongoing AML/KYC training for all relevant staff, covering:

- Legislation and regulatory requirements

- Detection of suspicious transactions

- Customer onboarding procedures

- Internal reporting obligations

- AML/CTF risk management practices

Training is mandatory and updated regularly.

## 11. Internal Controls & Compliance Oversight

The Bank maintains a robust internal AML/CTF control system including:

- A designated AML Compliance Officer

- Independent internal audits

- Regular compliance reviews

- Automated AML monitoring systems

These controls ensure ongoing effectiveness of the AML/KYC framework.

## 12. Prohibited Activities

Texas Capital Bank strictly prohibits:

- Anonymous account opening

- Shell bank relationships

- Cash-intensive transactions not supported by legitimate proof

- Transactions involving sanctioned individuals/entities

- Any activity inconsistent with global AML/CTF laws

## 13. Data Protection & Confidentiality

All customer information collected for AML/KYC purposes is handled with confidentiality and in accordance with data protection laws.
Information is shared only with regulatory authorities or as required by law.

## 14. Policy Review

This AML/KYC Policy is reviewed annually or whenever significant regulatory changes occur.
Updates ensure alignment with evolving AML/CTF standards and industry best practices.

## 15. Contact Information

For compliance inquiries or reports:

Email: [email protected]

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