Well, perhaps there is an issue. Under the BO regulation, §1010.230(b)(2), we see, at the end of that paragraph, this sentence:
"A covered financial institution may rely on the information supplied by the legal entity customer regarding the identity of its beneficial owner or owners, provided that it has no knowledge of facts that would reasonably call into question the reliability of such information."
That can be read to say that the bank in your case, has a duty to reconcile what's been claimed on the certification with what's in the company agreement.
John S. Burnett
Fighting for Compliance since 1976
Bankers' Threads User #8