Our company has a separate department that maintains solely doc custody functions including customer information files on corporations with trust accounts. The companies that hold the trust accounts in this area are currently being scanned against the FinCEN 314(a) list. The individual signers are not being scanned. Should we also be scanning the individuals who are the authorized signers / principles?

We search both the company and the signer at our bank because the system is automated. However, it's my understanding that you are not required to search signature cards to determine if a named subject is a signer on an account.