Does due diligence require asking 'Does this revenue derive from marijuana related activity?'
Can Financial Institutions disclose on a SAR that a subject appeared on FinCEN's 314a list?
Is a canabidiol (CBD) business legal at the Federal level. I understand it is legal in all 50 states but unsure about the Federal level. Would it be treated the same as a marijuana related business where a continuing SAR would be required?
What is an LEI? Do we have to use it to establish beneficial ownership certification?
Who signs the Beneficial Ownership Certification form where it
states " I,____, hereby certify, to the best of my knowledge, that the
information provided above is complete and correct ? The bank employee or the
Beneficial Owner who is opening the account?
Is it proper to release a copy of a check for a CTR that was filed? The agent want to know the source of funds.
We currently bank municipalities/public funds who are considering allowing medical marijuana business in their community. Sounds like it will cost about $5,000 per license upwards of 25-50 applications allowed. Do we need to report the activity in a SAR that the municipality is accepting applications?
123 LLC is owned by 2 individuals both at 33.33% and ABC, LLC which owns 33.34%. The natural individuals of ABC, LLC are John and Jane Doe. Would John and Jane Doe, in fact, be 16.67% owners of 123, LLC? This question is in regard's to the Certificate of Beneficial Ownership form.
Should a new Beneficial Owners Certification form be completed every time a new account is opened if there have been no changes in the beneficial ownership of the legal entity? Can the certification form currently on file be copied, re-signed and re-dated rather than complete a whole new form in those instances?
What address should we get on the W-8BEN?