Folks:

We are looking at a deposit account relationship with a company in town that manages farms in the area. The farm manager will be the only signer on accounts and will make all decisions re: money. The SSN on the accounts will be the farm owners.

Here's the CIP question: Our policy says we will rely on the agent to do the CIP and we will verify the documents of the agent only. But now that we are ready to put this into practice, why does this not feel kosher?

Should we have an agreement between us and the agent that says we are relying on his procedures but not actually checking those files? Should we document our files with copies of the farm management agreements between the owners and the agent? Should we all just wear our IDs glued to our foreheads?

Well, it probably does not feel kosher because you are letting go of what you know is an important control.
I think the bottom line on this is: if there is a problem, - say with someone being on OFACs list - you will probably be held responsible.
I think I would have an agreement, - I think I would reserve the right to inspect his files on the workers, and I think I would do that quarterly.
Also, because you are talking farms and the workers could be transient folks, I think I would ask for a list of the workers on a quarterly basis and run them through OFAC myself.
Just my thoughts.