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#458888 - 11/18/05 05:32 PM non resident alien
abanker Offline
Member
abanker
Joined: Oct 2002
Posts: 76
Colorado
We do not do business with non resident aliens because of IRS reporting requirements. My question is if the non resident alien is just a signer on an account he is not actually considered a customer right? Customer Identification Procedures, and IRS reporting do not come into play because he is just a signer correct?

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BSA/AML/CIP/OFAC Forum
#458889 - 11/18/05 06:07 PM Re: non resident alien
MagicCity Offline

Power Poster
MagicCity
Joined: Apr 2003
Posts: 3,003
Fort Lauderdale, Florida
IRS reporting is on the primary.
CIP depends on what your own policy says.
i.e. How have you defined 'customer'?

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#458890 - 11/18/05 06:10 PM Re: non resident alien
Elwood P. Dowd Offline
10K Club
Elwood P. Dowd
Joined: Aug 2001
Posts: 21,939
Next to Harvey
The CIP regulation does not consider a mere signatory to be a customer for the purposes of the regulation. Examples would be an authorized signer on a corporation's account or a clearly labeled convenience signer on an individual's account.

However, most banks adopted a CIP that requires them to ID mere signatories. Review your board adopted CIP. If it requires you to run mere signatories through your CIP process then that's "the law" within your bank; any outside evaluator will cite you for violating your own policy just as readily as they will cite you for violating the regulation.
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#458891 - 11/18/05 06:19 PM Re: non resident alien
WildTurkey Offline
Platinum Poster
WildTurkey
Joined: Jan 2003
Posts: 921
Down South, USA
Quote:

..... However, most banks adopted a CIP that requires them to ID mere signatories. ....



If you do not have a "CIP for signatories" policy you might want to consider one. Think about an extreme case - John Smith has an account and puts Osama Bin Laden on the account as a signatory, .... I assume that you would have a problem with that!
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This is my opinion; it is not legal advice, nor the view of my employer, and it may change tomorrow.

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