I disagree with Randy on this one. Verification of the identity of the individual beneficial owners is required but their status as beneficial owners is not. On page 40 of the Final Rule, it states, "FinCEN agrees that it would be impracticable for covered financial institutions to implement the beneficial ownership verification requirement with procedures that are identical to the institution’s existing CIP rule procedures for individual customers. Accordingly, § 1010.230(b)(2) has been amended to require that at a minimum, these procedures must contain the elements required for verifying the identity of customers that are individuals under paragraph (a)(2) of the applicable CIP rule, but are not required to be identical. In addition, the final rule clarifies that in the case of documentary verification, the financial institution may use photocopies or other reproductions of the documents listed in paragraph (a)(2)(ii)(A)(1)46 of the applicable CIP rule." It goes on to say that the verification must be completed within a reasonable time after the account is opened.
How that verification is completed (either by obtaining a copy of a driver's license or using an ID verification database) should be specified in your procedures.
_________________________
CAMS