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#316135 - 02/14/05 07:22 PM CIP & Payable Through Accounts
Anonymous
Unregistered

I know little about payable through accounts, but I'm learning.
Question: CIP says you don't have to CIP a signer unless you can't CIP the entity, etc...
Under the CIP rule, do you have to CIP signers on payable through accounts?
I am confused...!
Thank you..

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BSA/AML/CIP/OFAC Forum
#316136 - 02/15/05 03:18 PM Re: CIP & Payable Through Accounts
jerry Offline
New Poster
Joined: Aug 2004
Posts: 10
The feeling I get is that payable through accounts are problematic, especially those set up by your foreign correspondents. Examiners will expect rigorous due diligence on these accounts. One thing you don't have to do is look through a deposit broker's account to determine the identity of each individual sub-account holder.

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