The Bank has a few customers where their W8-BEN form has expired at the end of 2019. They have not signed updated forms. What, as the Bank, are we required to do? thank you,

Are these interest bearing accounts?

To Randy’s point, if they are interest bearing then you begin back-up withholding. From a BSA perspective you have the country of citizenship to help you understand normal and expected activity. Keep monitoring the account as you would any NRA.

Yes, I do have interest bearing accounts. Would it matter if the customer is a signer on Business accounts? Would I do back-up withholding on business accounts where for the NRA customer is a signer on an interest bearing business account or would I just back-up withholding on just the personal accounts?

Why do you even have a W-8BEN on a signer on a business account?

He has personal account along with the business accounts. I was not sure if the business accounts need it or has nothing to do with the W8-BEN form.