We have been receiving calls recently from individuals and corporations outside of our market area asking about certificates of deposits. What Due Diligence should be performed when the customer is not physically present?

If you are with a national bank, the OCC handbook, "Bank Secrecy Act/Anti-Money Laundering", has some guidelines for establishing relationships. Here is a link to OCC publications: http://www.occ.treas.gov/handbook/compliance.htm

LJW,
Unless you are a huge international bank, or one offering 20% interest on your time deposits, you have to ask, "why me?" "why this bank?". With the climate in this country as it is, I would be very nervous about someone I couldn't meet face-to-face, and a company who could not justify their reasons for picking my bank.
Just a thought.
Leslie

Even though this FFIEC guidance document was really designed for authentication of customers in an online environment, I believe you will find a number of helpful suggestions for the offline world in the section in it that deals with account origination and customer verification.

Please note: it is a pdf document, so you will need to have the Adobe Acrobat Reader.

Click here for the FFIEC document

LJW

Leslies comment should be taken seriously, always reminds me of the calls about money coming out of litchenstien as the reult of an isreali diamond deal through slovaki, can we accept the deposit?

We use a firm called CBI for this type of strange due diligence, thier telephone number is 805-658-8800 ask for Mike Adams - he's pretty good at listening to if you want to complain about some of the things you are made to investigate when you KNOW they arn't for real!

Matthew
Compliance Officers Assoc.
Privacy Officers ASSOC
AACFE, MICM.