If a Bank is approached by a Lead Agent to become party to a credit facility via an Amended and Restated Agreement and/or Joinder Supplement for an upsized commitment, what are its KYC, including CIP/CDD/Beneficial Ownership, obligations?
Hoping someone can opine. I'm auditing first line of defense noting this as issue and they are pushing back asserting that KYC is not triggered due to transaction occurring post original closing which I disagree with. From my perspective, we are on the amended note as a lender in the syndicate and performed full underwriting and credit approval.