SECURITY IDENTIFICATION POLICY PROCEDURES
I. Statement of Adoption and Implementation
American Train Destination Lines, hereinafter “ATD LINES” shall adopt and implement this Customer and Employee Identification Program (CEIP) as required by Section 326 of the USA PATRIOT Act and other international, national, state government, local codes, corporate policy of railway security and commercial business practices. ATD LINES CEIP consists of reasonable procedures for:
1). Verifying the identity of any person seeking to open an accounts, credit card/bank draft purchasing, employment, employee and admissions to ATD LINES properties offices or building to the extent reasonable and practicable;
2). Maintaining records of the information used to verify the person’s identity, including name, address and other identifying information; and
3). Determining if the person appears on any lists of known suspected terrorists, terrorist organizations, criminal back ground checks and special interest groups affiliations provided to ATD LINES by any government agency, special interest group association, railway security, law enforcement registrations or other public and private investigative resources.
This program covers formal business, employment and railway industry relationships such as accounts, extensions of credit, deposit, rentals, charters, cash management, contract agreements, custodian, trust, public safety and security services.
This program is not intended to cover the provision of products and services where no formal relationship is established, such as; accounts acquired through acquisitions, mergers, or purchases of assets; and accounts opened for the purpose of participation in employee benefit plans established pursuant to the Railroad Retirement Board or Employee Retirement Income Security Act of 1974 (ERISA).
II. Appointment of CEIP Compliance Officer
The ATD LINES Personnel Department and Office of Budget and Management is responsible for CEIP Compliance Administration. The CEIP Compliance Officer is responsible for:
A). Day-to-day implementation and administration of the ATD LINES CEIP program and employee training;
B). Drafting corporate-wide CEIP procedures for management review and approval;
C). Development of a corporate-wide CEIP employee training program for management approval; and
D). Recommending to management any modifications that may be necessary.
Compliance review, testing and periodic reporting will be performed by the compliance officer.
III. Customer and Employee Information Collection and Verification Documentary Methods
ATD LINES corporate personnel and representatives of company shall employ the following procedures in conjunction with opening business and government relations, account management, other railway business affairs and security. Existing customers, business client, railway representatives are exempt from the identification verification process to the extent that the employees and security checks has a reasonable belief that ATD LINES has previously verified their identity, and that sufficient records exist to support the previous verification.
The ATD LINES does open new accounts via the Internet or by mail. Railway Business Clients and new employee's, new railway account representatives and customers security clearance are required to be presenting “face-to-face” before an account or business transaction will be offered. As part of ATD LINES training, employees receive a Risk Assessment Matrix which addresses the degree of inherent risk and verification procedures required for all new account, employment, and security circumstances they should encounter.
At a minimum, employees of the ATD LINES are instructed to obtain the following information from the customers, contacts security issues prior to opening any business relation:
2). Date and Place of birth,
3). Address, which must be one of the following, as appropriate:
a). For an individual, a residential or business street address;
b). For an individual who does not have a residential or business street address, an Army Post Office or Fleet Post Office box number, or the residential or business street address of the next of kin or of another contact individual; or
c). For a person other than an individual (such as a corporation, partnership or trust) a principal place of business, local office, or other physical location; and Identification number, which must be verified by of the following, as appropriate:
A). For a U.S. Citizen Bearing Photograph and Finger Prints:
1). Taxpayer Identification Number,
2). Corporate or Business Identification Number,
3). Passport Number,
4). Department of Labor Number,
5). Interstate Commerce Certification,
6). SIC Classification Number,
7). Social Security Number,
8). Railroad Retirement Board Number,
9). Armed Forces Number,
10). Government Agency Identification Number.
B). For a non-U.S. Citizen Bearing Photograph and Finger Print:
1). A taxpayer identification number;
2). Passport number and country of issuance;
3). Alien identification card number;
4). Number and country of issuance of any other government-issued document evidencing nationality or residence and bearing a photograph or similar safeguard; or
5). If a foreign business or enterprise does not have an identification number, the employee must request alternative government issued documentation certifying the existence of the business or enterprise. Exception for persons applying for a taxpayer identification number:
a). A copy of the application for a TIN filed prior to opening the account. Subsequent to opening the account, the employee will follow up with the customer to obtain the TIN within 45 days after the account is opened. Failure to provide the TIN within 45 days of opening an account will result in closing of the account and return of the account balance to the customer.
b). For an individual: with non-expired government-issued identification evidencing nationality or residence and bearing a photograph or similar safeguard, such as a driver’s license or passport.
c). For a person other than an individual (such as a corporation, partnership or trust), documents showing the existence of the entity, such as certified articles of incorporation, a government-issued business license, a partnership agreement, or trust instrument.
IV. Non-documentary Methods
The following procedures shall be employed in situations where the customer is unable to produce the primary identification requested:
1). Examination of an expired passport, driver’s license, or other government issued ID card, bearing a photograph of the customer; or
2). Contacting the customer, client, individual or business officer or internet verification after communications is established, at the address and/or telephone number provided; or
3). Obtaining current documents to reviews statements and investigation verifying the data provided therein; or
4). Contacting other institutions with which the customer, client, individual has previously maintained a relationship; and
5). Verifying information provided through law enforcement agency, security background check.
V. Lack of Verification
Should an occasion arise when an employee, individual, client, customer, security check of ATD LINES cannot, based on the verification procedures outlined herein, form a reasonable belief that they know the true identity of a customer, the employee should not open an account or proceed to consummate business transaction or communications.
VI. Record Keeping
Documentation obtained and utilized to verify the identity of customers, individuals, clients, employees will be described in records (signature cards, credit application, etc.) and retained for the period during which the record is open or outstanding for security procedures or 10 years after the record is closed or becomes dormant. Documentation will include:
1). A copy or description of any document that was relied on for the verification of identity. The retained information shall reflect any identification number, the place of and, if any, the date of;
2). Certified Articles of Incorporation, Partnership or LLC Agreement, government-issued business license, or trust instrument;
3). A copy of the ChexSystems scan and/or a copy of the credit report from Equifax or TransUnion; and
4). A copy or description of the resolution of any substantive discrepancy discovered when verifying the identifying information obtained.
VII. Comparison with Government Lists
The ATD LINES shall compare all new customers, individuals; business clients against a government issued list of known suspected terrorists, terrorist organizations, criminals and known data. The ATD LINES utilizes the list provided by the International, National, Federal, State, Local Governmental Department or Agency, or other registry lists.
All new customers, employees, security checks and individuals are subject to criminal back ground, educational, credit or other investigation checks, prior to account opening, employment access to properties. In addition, the ATD LINES will contract with data processing investigation service. ATD LINES Administration personnel, security services for possible matches, will review reports. Any matches are referred to ATD LINES Security Operations Officer for further investigation and resolution. In addition to the ATD LINES Security Officer is designated as the contact person to receive e-mail transmissions of the FBI Control List or other agency list.
VIII. Customer Notice
The following notice is prominently displayed at all locations where ATD LINES offices, Internet web services are opened and where Railway Business is consummated:
IX. Homeland Security
On September 11th, 2001 our lives changed forever when our country was attacked. In an effort to protect ATD LINES Clients, customers, visitors, employees and our country, President Bush signed the USA Patriot Act into law on October 26, 2001. To help the government fight the funding of terrorism and money laundering and other criminal activities, Federal law requires all security institutions to obtain, verify, and record information that identifies each person. When doing business with ATD LINES, will ask specific information as to name, address, date and place of birth, and other information that will allow ATD LINES to identify customers, individuals, clients and others. ATD LINES will ask to visual verification identification or other identifying documents and make copies for files/records at the ATD LINES. This same type of identification will be requested of others coming in contact with ATD LINES Security Representatives or Agents. In all cases, protection of your identity and the confidentiality of this information are our pledge to the American Society, Business Protection and Public Safety.
We proudly support all efforts to protect and maintain the security of our customers and our country.