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Information regarding Bank of the West and anti-money laundering policies and procedures

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"). We are a subsidiary of BancWest Corporation, which itself is a subsidiary of BNP Paribas, headquartered in Paris, France.

We are a state chartered bank, headquartered at 180 Montgomery Street, San Francisco, California, in the United States of America (USA). Our primary federal regulator is the Federal Deposit Insurance Corporation (FDIC), 550 17th Street NW, Washington, DC 20429-9990, USA.

We are a full-service commercial bank. We originate commercial, small business, and consumer loans and leases, and offer a range of other individual and commercial banking, trust, and investment products. Additional products are offered through our subsidiaries: BancWest Investment Services offers investment products; Essex Credit Corporation offers loans on marine pleasure craft and recreational vehicles; and BW Insurance Agency, Inc., offers auto, homeowners, workers compensation, and general liability insurance. We currently operate physical branch locations in 19 states in the USA: Arizona, California, Colorado, Idaho, Iowa, Kansas, Minnesota, Missouri, Nebraska, Nevada, New Mexico, 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 Administrator, 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 Krenitsky, 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 Krenitsky
Chief Compliance Officer, Executive Vice President, Corporate Compliance
Executed on this 16st day of June, 2013

Our Wolfsberg Anti-Money Laundering Questionnaire