Anti-Money Laundering and Anti-Terrorist Financing Policy

Fulton Online Bank has adopted an Anti-Money Laundering and Anti-Terrorist Financing Policy ("Policy") to:

  • Minimize the risk that Fulton Online Bank or its employees inadvertently become involved in money laundering or terrorist financing activities;
  • Help protect the safety, soundness and reputation of Fulton Online Bank by reducing the likelihood that Fulton Online Bank will be used as a vehicle for, or become a victim of, financial crime; and
  • Help facilitate compliance with all applicable regulatory requirements relating to anti-money laundering ("AML") and anti-terrorist financing ("ATF") in each country in which Fulton Online Bank operates

The Policy and related standards (covering such topics as Client Due Diligence ("CDD") (also referred to as "know your customer") and Politically Exposed Persons ("PEPs")), are applicable to all divisions of Fulton Online Bank (including its foreign branches and offices) and its wholly-owned subsidiaries globally (collectively referred to as "Fulton Online Bank"), and meet or exceed the AML/ATF regulatory standards in each country in which Fulton Online Bank operates.


Fulton Online Bank has implemented procedures to ensure that relevant regulatory obligations with respect to reporting of large cash transactions, electronic funds transfers and cross-border movements of cash and monetary instruments are met in each jurisdiction.


Fulton Online Bank has appointed a Chief Anti-Money Laundering Officer ("CAMLO") who is responsible to senior management and the board of directors for establishing and maintaining Fulton Online Bank's AML/ATF Program. The CAMLO has appointed a Regional AML Officer and a Regional Money Laundering Reporting Officer ("MLRO") in each geographic region in which Fulton Online Bank operates. In addition, the executive responsible for each line of business must designate one employee within the business to be the Line of Business AML Officer, with primary oversight responsibility for AML/ATF compliance within that business.


All new employees are required to compete Fulton Online Bank's AML/ATF training within thirty (30) days of commencing employment, and thereafter are required to complete AML/ATF refresher training in accordance with Fulton Online Bank standards.


All Fulton Online Bank employees worldwide are required to report any identified unusual transaction or activity to the appropriate Fulton Online Bank AML Group. The AML Group will conduct an analysis to determine whether the information may indicate money laundering or terrorist financing, and requires submission of a report to the appropriate authority.

A Global Organization

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