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#2110807 - 12/14/16 07:24 PM CDD/Beneficial Ownership and KYCC
BSAN3rd Offline
Junior Member
Joined: Sep 2016
Posts: 32
Hi all,

I am not sure if this question is one that can readily be answered but I figured I'd give it a shot here.

For those banks who are doing business with TPPPs... will there be an expectation that we will get the Beneficial Ownership information for our Customer's Customers?

For example, if my customer is ABC TPPP Co and their customer is XYC Company, am I going to be required to add the BO Form to the list of documents that we obtain when verifying our customer's customer as XYC Company? There is already so much emphasis put on the CDD requirements - I just wasn't sure if it extends that far.

Thanks

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#2110833 - 12/14/16 08:53 PM Re: CDD/Beneficial Ownership and KYCC BSAN3rd
Elwood P. Dowd Offline
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Elwood P. Dowd
Joined: Aug 2001
Posts: 21,939
Next to Harvey
The new regulation has no special impact on your responsibilities regarding TPPP customers; eventually, you will have to identify their beneficial owners just like any other legal entity that opens an account with you. If you have a constantly updated list of your customer's customers, you are probably well ahead of the pack. If you require beneficial ownership information on any or all of them it will be driven by an internal decision.
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#2111812 - 12/22/16 01:30 PM Re: CDD/Beneficial Ownership and KYCC BSAN3rd
BSAN3rd Offline
Junior Member
Joined: Sep 2016
Posts: 32
Thank you for replying. smile

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