Skip to content
BOL Conferences
Thread Options
#2178357 - 05/16/18 05:32 PM Minor Identified as Beneficial Owner
TryingtoComply Offline
Diamond Poster
Joined: Apr 2013
Posts: 2,210
The West
For the second time, I have been notified that a BO is a minor. Anyone else experiencing this? What have you decided to do with respect to ID? In this case the minor is 13 years old.
_________________________
TryingToComply
CRCM

Return to Top
BSA/AML/CIP/OFAC Forum
#2178372 - 05/16/18 06:00 PM Re: Minor Identified as Beneficial Owner TryingtoComply
Daisy Doodle Offline
Diamond Poster
Joined: Feb 2014
Posts: 1,030
Southern U.S.
We just recently closed an account and filed a SAR because Dad registered a company in his minor son's name. We did not think there was a benign reason for this in our situation.

Minor's cannot legally contract, so how would this work for a business?

Return to Top
#2178374 - 05/16/18 06:16 PM Re: Minor Identified as Beneficial Owner TryingtoComply
Elwood P. Dowd Offline
10K Club
Elwood P. Dowd
Joined: Aug 2001
Posts: 21,939
Next to Harvey
What does your CIP say about identification for someone who, due to age or disability, has no identification that matches your program requirements? Follow that.
_________________________
In this world you must be oh so smart or oh so pleasant. Well, for years I was smart. I recommend pleasant.

Return to Top
#2178414 - 05/16/18 08:10 PM Re: Minor Identified as Beneficial Owner TryingtoComply
TryingtoComply Offline
Diamond Poster
Joined: Apr 2013
Posts: 2,210
The West
Not addressed in our procedures. I didn't write them.....

What are others doing?
_________________________
TryingToComply
CRCM

Return to Top
#2178422 - 05/16/18 08:23 PM Re: Minor Identified as Beneficial Owner TryingtoComply
Daisy Doodle Offline
Diamond Poster
Joined: Feb 2014
Posts: 1,030
Southern U.S.
It better be a lemonade stand, that's my stance. Otherwise, a minor's interest in a real business would be handled by a guardian or trustee I would think.

Return to Top
#2178423 - 05/16/18 08:26 PM Re: Minor Identified as Beneficial Owner TryingtoComply
TryingtoComply Offline
Diamond Poster
Joined: Apr 2013
Posts: 2,210
The West
Daisy,

Are you suggesting that we obtain the name and ID of the guardian?
_________________________
TryingToComply
CRCM

Return to Top
#2178426 - 05/16/18 08:33 PM Re: Minor Identified as Beneficial Owner TryingtoComply
Daisy Doodle Offline
Diamond Poster
Joined: Feb 2014
Posts: 1,030
Southern U.S.
I haven't had to face this, so I don't have a feel for the circumstances where it would take place.

If you opened a personal checking account for that minor, that is what you would do. Couldn't you show the BO as John Doe, Guardian for Robert Doe, minor and get the guardian's ID and info?

Return to Top
#2178450 - 05/16/18 09:44 PM Re: Minor Identified as Beneficial Owner TryingtoComply
rlcarey Offline
10K Club
rlcarey
Joined: Jul 2001
Posts: 83,350
Galveston, TX
The minor has a court appointed guardian??
_________________________
The opinions expressed here should not be construed to be those of my employer: PPDocs.com

Return to Top

Moderator:  Andy_Z