Anti-Money Laundering

Bank of America has an enterprise-wide Anti-Money Laundering (AML) program, which covers all of its subsidiaries and affiliates, and is reasonably designed to comply with applicable laws and regulations. Should you or your institution require general information about Bank of America’s AML compliance program, please see the following:

Financial Crimes Enterprise Policy Statement

It is the policy of Bank of America (“the Company”) that it will not knowingly commit or facilitate financial crime by, at or through the Company; and, that it will fully cooperate within the bounds of the law with competent authorities conducting investigations of financial crime. In fulfilling this policy, the Company may terminate customer relationships based on suspicion of criminal activity or based upon a determination that a customer presents financial crimes risk outside the Company’s risk appetite; however, the Company does not arbitrarily de-risk portfolios of customers based upon perceived risks. The Company does not terminate customer relationships based upon race, color, religion, sex, marital status, age (provided the customer has reached the age to enter into contracts), familial status, disability, gender identity or sexual orientation.

It is also the Company’s policy to fully comply with the laws, rules and regulations relating to financial crimes wherever we do business. Any Company employee who knowingly commits or facilitates a financial crime; knowingly violates a law, rule, or regulation covered by this policy; or knowingly violates this policy or a related standard can be subject to disciplinary action up to and including termination. If appropriate, the Company may refer such employee to a competent regulatory or law enforcement authority for appropriate action.

Bank of America AML and Economic Sanctions Compliance Program

Bank of America has developed an Anti-Money Laundering Compliance and Economic Sanctions Compliance Program to comply with applicable laws and regulations. Please click the following link to view and/or print a letter from Bank of America’s Global Financial Crimes Compliance Executive.

Bank of America AML Compliance Program Letter

Bank of America AML Questionnaire

Bank of America has also prepared an AML Questionnaire, based on Wolfsberg’s publication of the Banker’s Almanac AML Questionnaire, for use by any financial institution that requires more detailed information about Bank of America’s AML compliance program. Please click below to view/print the questionnaire.

Bank of America AML Questionnaire

Patriot Act Certification

Bank of America has prepared a global certification for use by any financial institution that requires a Patriot Act Certification (PAC) for a Bank of America foreign entity. Please click the below link to view/print our Patriot Act Certification.

Bank of America PAC