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#2248181 - 01/26/21 05:39 PM Beneficial Owner Existing Customer - New Business
JackieW Offline
New Poster
Joined: May 2019
Posts: 20
An existing customer opened a personal account 10 years ago. That customer is now opening a new account for a new business and is a beneficial owner of the business. The DL information obtained at the time the personal account was opened is now expired. For the Certification of Beneficial Owner form for the new business account, does the DL information need to be current on the beneficial owner?

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#2248182 - 01/26/21 05:41 PM Re: Beneficial Owner Existing Customer - New Business JackieW
RockChucker, CAMS Offline
Diamond Poster
Joined: Jul 2013
Posts: 1,657
The Country
Maybe I missed something but I was under the impression that the DL was not a required piece of information on the BO form.
A successful man is one who can lay a firm foundation with the bricks others have thrown at him.
-David Brinkley

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#2248189 - 01/26/21 06:05 PM Re: Beneficial Owner Existing Customer - New Business JackieW
rlcarey Online
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Joined: Jul 2001
Posts: 79,649
Galveston, TX
Well, procedures must contain the elements required for verifying the identity of customers that are individuals under 31 CFR 1020.220(a)(2), provided, that in the case of documentary verification, the bank may use photocopies or other reproductions of the documents listed in paragraph (a)(2)(ii)(A)(1) of 31 CFR 1020.220.
The opinions expressed here should not be construed to be those of my employer:

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