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#2066569 - 02/29/16 05:19 PM Company's business license-expired or revoked
Victoria S Offline
Member
Joined: Jul 2015
Posts: 93
Scenario: ABC Roofing maintains 2 business accounts. Bank recently discovered business licenses have been revoked.

What is the proper course of action? Insist the account be closed?

Please advise.

Thanks.

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BSA/AML/CIP/OFAC Forum
#2066583 - 02/29/16 05:46 PM Re: Company's business license-expired or revoked Victoria S
rlcarey Offline
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rlcarey
Joined: Jul 2001
Posts: 77,238
Galveston, TX
I would make an inquiry to the company and give them xx days to provide proof that they are again licensed prior to accepting additional transactions. This is not really a BSA/AML issue, more of a reputational risk avoidance practice now that you know.
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#2066589 - 02/29/16 05:50 PM Re: Company's business license-expired or revoked Victoria S
Pat Patriot Act Offline
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Pat Patriot Act
Joined: Apr 2009
Posts: 450
I agree with rlcarey here - notify the customer to have them update the documentation. It's not directly a BSA compliance issue in 2016 unless you've exempted them, but it may be in 2018 when the CDD NPRM most likely goes into effect.
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#2066590 - 02/29/16 05:51 PM Re: Company's business license-expired or revoked Victoria S
edAudit Offline
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edAudit
Joined: Jul 2008
Posts: 4,714
You are here
agreed with the above but will like to add

It's not directly a BSA compliance issue until the CMP show up.
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#2066614 - 02/29/16 06:27 PM Re: Company's business license-expired or revoked rlcarey
Victoria S Offline
Member
Joined: Jul 2015
Posts: 93
Appreciate your input.

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