Would anyone be able to advise on how to properly title an account for a "Consulate". And, what other documentation would you require per recent guidance?

Banking consulates, embassies, ministry offices, government attaches is a very specialized area, and requires a fair amount of expertise.

Borrowing a phrase from RLCarey, "It's easier to bank 50 embassies than it is to bank 1 or 2."

Anyway, on to your question. One of the pieces of documentation you will need is an original letter from the Secretary/Minister of State of the country identifying the person and authorizing them to conduct business on the government's behalf.

Be prepared to review all of their transactions every month.

You might want to read this for some background material.

http://www.fincen.gov/news_room/rp/files/sar_tti_19.pdf

To title the account should it be The Consulate of XYZ Country as the "Consulate" is the appointed individual. And should it be titled as The Consulate of XYZ Country would it need to have its own TIN not the individuals TIN?

The 2011 Guidance was issued because similar organizations are experiencing increasing levels of difficulty in finding banks willing to deal with them. Banks with decades of experience and expertise in this specialized area have simply discontinued this line of business. That discontinuance is based in part in their reassessment of risk levels and in part on the erratic regulatory attention these relationships have drawn. (The Guidance was intended to homogenize the regulatory approach.) The U.S. Department of State is distressed about the circumstance and played a role in the issuance of the interagency guidance.

If your bank has done a detailed risk assessment and decided that it's a good time to enter this business, I admire your chutzpah. You are clearly willing to swim upstream. However, if your bank is opening its first account for this type of customer simply because someone asked you to, my opinion is that it is making a flagrant error.

The questions you are asking suggest that it's the latter scenario.

At a minimum, your risk assessment and your BSA policy should be updated before you do this. When you explain your requested policy changes to the board, make certain you tell them about Riggs National and that customers such as this one are classified as "subject to expanded examination overview." Provide them with copies of both the 2011 Guidance and the 2004 Guidance. You should talk to bankers or consultants experienced in the subject matter and develop your relevant procedures in advance. Each proposed account should have its own risk assessment prior to opening. Your fee schedule should reflect the additional work and the assumption of risk involved.

This is the deep end of the risk pool.

Small point, but the Consul/Attache/whatever would not be an American citizen. Also, think of the Consulate as a business. It may have multiple accounts for different purposes. It will receive wires from its home country, it may collect fees of various kinds, it will pay employees, rent space, etc. It will also have the normal household and living expenses of the Consul and the their family. Think of the Consulate as a business, staffed by PEPs, and employing people who may be considered PEPs, but with regular household expenses thrown in.

Ken's point is well taken; the Dept of State and Dept of the Treasury are often at cross-purposes. I remember an incident at a bank long ago and far away where the Secretary of State asked the bank to open an Embassy account for a country with which Treasury barred transactions.

Just to emphasize the point: A Consul is an individual appointed by a government to reside in and represent his government's commercial interests in a foreign country, and to assist countrymen and women visiting that country. The consulate is the consul's residence and place of business.