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#372732 - 06/14/05 04:54 PM CIP - International agency

As an international agency/branch of a foreign bank, we perform transactions for non-account holders. (No cash involved, mainly wires/SWIFT) Transactions could be one time or perhaps once a month.

Since they do not have an account relationship as defined in the CIP rules, are we okay? Or should there still be some sort of due diligence.

We obtain their ID information at the time of transaction.

Any advice / guidance would be appreciated. Thank you.

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#372733 - 06/14/05 05:14 PM Re: CIP - International agency
Hrothgar Geiger Offline
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Hrothgar Geiger
Joined: Jun 2005
Posts: 10,395
Jersey Shore
What you describe sounds suspiciously like a 'payable through account'.... maybe I'm misunderstanding what you mean.

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#372734 - 06/16/05 05:25 PM Re: CIP - International agency

Thanks AML

Anyone else with comment?

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