Also a non subscriber.
The only triggering event for obtaining the certification under the regulation is the opening of a new account. Based on guidance issued several years ago, banks should already know the beneficial owners of their "higher risk" customers. I can make a case that, for the sake of form over substance, banks should periodically update the beneficial ownership information for those higher risk customers; e.g. during annual reviews, if they have not opened an account in the interim.
Beyond that, obtaining "new" unconfirmed information because of XX is a ridiculous waste of time. Using a wire transfer as a triggering event would be a good example. (It would also defy an intelligent explanation for the request you could offer to the customer; e.g. you sent/received a wire transfer so we need to know who owns your company?)
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In this world you must be oh so smart or oh so pleasant. Well, for years I was smart. I recommend pleasant.