My bank currently has a large loan for a US entity which will be guaranteed by two foreign entities based in China. I'm trying to determine exactly what I need to do concerning CIP for these entities. I have been provided with their name and address and can verify this information via the internet. However, I am being told that they will not be providing any type of operating agreements or tax ID numbers. We will be running OFAC on each foreign business but is there something else that I should require to satisfy BSA requirements other than my own EDD for all entities involved with this transaction? Do other institutions require documentation on authorized signers or beneficial owners (I know we will all be going that way soon)? The risk officer for the bank is only concerned with knowing what is explicitly required under BSA.
Thanks in advance for any help you can provide.