As you note, there is an explicit exception in the CIP FAQ (which provides the definition of "account" and "new account" for use in the BenOwn rules) for purchased loans, which included participations. However, syndicated loans don't fall within that exception, since the syndicate is formed before a loan is made, and the loan is made by the syndicate (regardless of the moving parts in the actual closing). Hence, each syndicate member will either have to do its own CIP and BenOwn work or depend on the lead lender in the syndicate to do so as agent on behalf of the syndicate members.
John S. Burnett
Fighting for Compliance since 1976
Bankers' Threads User #8