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M&T Bank Corporation and Manufacturers & Traders Trust Company

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Written Agreement
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On June 17, 2013, the Federal Reserve Board released a Written Agreement with M&T Bank Corporation (M&T) and one of its subsidiaries, Manufaturers & Traders Trust Company (Bank), both of Buffalo, New York.

M&T is a bank holding company that also owns and controls various non-bank subsidiaries, including Wilmington Trust Company, Wilmington, Delaware (WTC). WTC voluntarily surrendered its FDIC insurance and became a non-bank in 2011. WTC provides a variety of products and services to private and institutional customers, including wealth advisory and foreign correspondent account services.

M&T had adopted a firm-wide compliance risk management program for its subsidiaries, including the Bank, designed to identify and manage compliance risks related to BSA and AML requirements. M&T also undertakes to conduct customer due diligence and transaction monitoring on behalf of its subsidiaries. The FRB of New York identified, in its most recent inspection of M&T, deficiencies in M&T's firm-wide compliance risk
management program with respect to compliance with BSA/AML Requirements; the Bank's internal controls, customer due diligence procedures, and transaction monitoring processes with respect to compliance with BSA/AML Requirements; and WTC's due diligence practices for foreign correspondent accounts.

The Written Agreement requires that M&T adopt, submit and adhere to an acceptable revised written firm-wide BSA/AML compliance program that describes the specific actions that will be taken, including timelines for completion, to ensure compliance with applicable BSA/AML Requirements. Required elements of that program are spelled out, including the findings and recommendations of a consultant "recently engaged by M&T to assist in matters related to compliance with the BSA/AML Requirements."

The Bank agreed to engage an independent consultant to conduct a review of account and transaction activity associated with high--risk customer accounts from 7/1/12 to 12/31/12, to determine whether suspicious activity was appropriately reported. The Reserve Bank may order similar reviews for other time periods

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