Bank of the West is fully committed to remaining constantly vigilant to prevent the use of our products and services by those who would abuse them.

The following is for use by any financial institution seeking information about Anti-money Laundering or Know Your Customer programs at Bank of the West ("the Bank").

Bank of the West is a trade name of BMO Harris Bank N.A. BMO Harris Bank N.A. is a national bank with its main office located at 320 S. Canal Street, Chicago, IL 60606, USA.  Our primary federal regulator is the Office of the Comptroller of the Currency (OCC), www.occ.gov.

We are a full-service commercial bank. We originate commercial, small business, and consumer loans and leases, marine and recreational vehicle loans, and offer a range of other individual and commercial banking, trust, and investment products. Additional products and services are offered through BancWest Investment Services, which offers investment products and is a subsidiary of BMO Harris Bank N.A. We operate physical branch locations under the trade name Bank of the West in 20 states in the USA: Arizona, California, Colorado, Idaho, Iowa, Kansas, Minnesota, Missouri, Nebraska, Nevada, New Mexico, New York, North Dakota, Oklahoma, Oregon, South Dakota, Utah, Washington, Wisconsin, and Wyoming.

We are subject to the anti-money laundering laws and regulations of the USA. The Bank Secrecy Act (BSA) and the USA PATRIOT Act are the primary regulations in the USA designed to prevent money laundering. In accordance with these regulations, we have established:

• A written Bank Secrecy Act/Anti-money Laundering Program that is reviewed and approved annually by our Board of Directors and is subject to review by our federal regulators
• Written policies and procedures designed to combat money laundering and terrorist financing
• A written Customer Identification Program (CIP) whereby new customers are identified prior to inception of a business relationship
• Written policies and procedures designed to ensure compliance with sanctions administered by the U.S. Office of Foreign Assets Control (OFAC)
• An employee training program to educate employees about money laundering and terrorist financing crimes, to assist them in identifying suspicious activities
• Procedures for monitoring accounts and transactions for suspicious activities, and for filing reports with the appropriate authorities if suspicious or structured activity is detected
• An independent audit review function to test the adequacy of our anti-money laundering policies and procedures on an annual basis
• A BSA Officer, who is appointed by our Board of Directors and is responsible for the oversight of our anti-money laundering program
• The Bank's anti-money laundering policies and procedures apply to all of our branches and subsidiaries.

We are prohibited under the Bank Secrecy Act from opening or maintaining accounts on behalf of foreign shell banks. Furthermore, we do not permit foreign banks that maintain correspondent accounts with us to indirectly provide banking services to shell banks.

I, John McCarthy, certify that the above information is true and correct and that I am authorized to sign this statement on behalf of Bank of the West.

John McCarthy
AML Officer, Enterprise AML

Executed on this 1st day of February, 2023

Wolfsberg Questionnaire

Securities and variable annuities are offered through BancWest Investment Services, a registered broker/dealer, member FINRA/SIPC, and SEC Registered Investment Adviser. BancWest Investment Services, Inc. is a subsidiary of BMO Harris Bank N.A. Financial Advisors are Registered Representatives of BancWest Investment Services. Fixed annuities/insurance products are offered through BancWest Insurance Agency and/or BancWest Investment Services, Inc. in the states where we are licensed to do business.  This is not an offer or solicitation in any jurisdiction where we are not authorized to do business. BMO Harris Bank N.A. and its various affiliates and subsidiaries are not tax or legal advisors.