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#2207824 - 03/05/19 05:27 PM DOEP - Acccuracy of Eligibility Percentages
CoSmIc GoPhEr Offline
Junior Member
Joined: Apr 2013
Posts: 31
Are we there yet?
Can we take the word of the account owner when it comes to the eligibility percentages for a DOEP similar to how the ownership percentages of the beneficial ownership form are handled? We have a customer claiming their "ineligible activities" are 10% when the activity in the account seems to say otherwise.

Not sure how nit-picky we need to be.

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#2207830 - 03/05/19 06:05 PM Re: DOEP - Acccuracy of Eligibility Percentages CoSmIc GoPhEr
bcompliance Offline
Diamond Poster
Joined: Sep 2014
Posts: 1,294
We have our Phase II DOEPs sign a letter attesting that their gross revenues for ineligible activities (spelled out in the letter) are less than 50% annually. If you don't believe that the activity is less than 50% of their gross revenue for ineligible activities, revoke their exemption and start filing CTRs on them.
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CRCM, CAMS

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#2207853 - 03/05/19 08:14 PM Re: DOEP - Acccuracy of Eligibility Percentages CoSmIc GoPhEr
TryingtoComply Offline
Diamond Poster
Joined: Apr 2013
Posts: 2,199
The West
They may not be using your bank for all their banking needs. Get financial statements.
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TryingToComply
CRCM

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