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#1979888 - 12/01/14 03:54 PM Israeli Citizens and doing business in US - HELP!
CantBeShocked Offline
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Joined: Apr 2006
Posts: 260
MS
We recently opened a checking account for an LLC owned by three Israeli citizens who bought a foreclosed business building in our city - they paid for it outright. They all have Visa types R/B1-B2 and no SSNs or ITINs. They provided Visas and Passports at account opening and signed Form W-8BENs.

They now would like to obtain a $40k letter of credit for the business (not sure who are guarantors -- we are asking). The LofC has to do with Entergy services and we feel that this LofC will lead to other requests for operational credit loans or improvement loans etc. However we are unsure how to proceed!

What additional information should we obtain in order to provide this LofC or should we be concerned? As the BSA Officer I am concerned that they paid outright for the building but I cannot find anything about them other than that they recently bought another foreclosed commercial property in Michigan.

Any input will be helpful!!!

Thank you!
Last edited by The Real Mobo; 12/01/14 03:54 PM.
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#1979898 - 12/01/14 04:32 PM Re: Israeli Citizens and doing business in US - HELP! CantBeShocked
Daisy Doodle Offline
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Joined: Feb 2014
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Southern U.S.
I do not know what size your bank is, or how much international type activity you do. It is entirely possible that the bank should pass up an opportunity if it is outside of your experience and ability to conduct due diligence or monitor. We have done that before--in fact at the time we were suspicious they would come to a community bank for such a request.

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#1979905 - 12/01/14 04:45 PM Re: Israeli Citizens and doing business in US - HELP! CantBeShocked
ACBbank Offline
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ACBbank
Joined: Jul 2006
Posts: 3,959
New York City
Underwriting aside,in terms of the LLC, was it established in the US? If not, you may want to ensure that the identification number obtained is acceptable to your written CIP.

You most certainly can inquire about source of funds/origin of wealth used to buy the building.
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#1979932 - 12/01/14 05:26 PM Re: Israeli Citizens and doing business in US - HELP! CantBeShocked
CantBeShocked Offline
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Joined: Apr 2006
Posts: 260
MS
Yes the LLC was formed in the US and has a taxpayer ID number. My question is mainly in regards to the members of the LLC who would be guarantors on the LofC. They are either somewhat ignorant of what is required or they are "playing dumb". I really need to understand if they can, in fact, be guarantors on the letter of credit and have only B1 visas. I assume yes since they can sign contracts and create a business legimately - they can not be receive payroll in any form, however, without a different type of Visa.
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#1980172 - 12/02/14 02:01 PM Re: Israeli Citizens and doing business in US - HELP! CantBeShocked
Elwood P. Dowd Offline
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Quote:
I really need to understand if they can, in fact, be guarantors on the letter of credit and have only B1 visas. I assume yes since they can sign contracts and create a business legimately - they can not be receive payroll in any form, however, without a different type of Visa.


Actually, all that affects is the quality of the credit, not BSA compliance. Tell your lender(s) that it just dawned on you this morning that this is their issue to resolve, not yours.
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