Skip to content
GeoDataVision
Thread Options
#958241 - 05/13/08 03:03 PM Mexican Consulent Business
crazed Offline
Member
Joined: Dec 2005
Posts: 61
A Mexican Consulent Business has opened an account with our bank. They do not have, and say they don't have to have, a federal tax ID number. Well guess what.............now we are in a situation where we need to file a CTR on this business. How do we complete a CTR without an EIN to report?? HELP!!!!

Return to Top
BSA/AML/CIP/OFAC Forum
#958279 - 05/13/08 03:54 PM Re: Mexican Consulent Business crazed
KYAuditor Offline
100 Club
KYAuditor
Joined: Jan 2003
Posts: 138
Kentucky
I'm not an expert on this type of business, but why would they not need a Tax ID number? Even if they did not need it for other reasons, they can still obtain a number for banking purposes.

Our CIP policy requires that they provide us with a number or we would close the account. Check your CIP program to see if this is addressed. If not, I would require them to get a number or close the account. I don't know of any exemption on CTR reporting for not providing a Tax ID number. Maybe one of the experts will weigh in on this.

Hope this helps.
_________________________
Just my 2 cents worth--for what its worth!!

Return to Top
#958295 - 05/13/08 04:18 PM Re: Mexican Consulent Business KYAuditor
John Burnett Offline
10K Club
John Burnett
Joined: Oct 2000
Posts: 39,684
Cape Cod
Crazed:

What do you mean by "Consulent" business?

When the person listed on a CTR does not have a TIN, the instructions for items 6 and 19 are pretty clear: "If none, write NONE," and "If the individual does not have an SSN/TIN, enter NONE."
_________________________
John S. Burnett
BankersOnline.com
Fighting for Compliance since 1976
Bankers' Threads User #8

Return to Top
#958409 - 05/13/08 06:07 PM Re: Mexican Consulent Business John Burnett
Little Miss BSA Offline
Diamond Poster
Little Miss BSA
Joined: May 2007
Posts: 1,185
Miami
I think they meant to say consulate - which is an account usually maintained for or by a foreign government.
_________________________
"Never allow someone to be your priority while allowing yourself to be their option!"

Return to Top
#958411 - 05/13/08 06:09 PM Re: Mexican Consulent Business Little Miss BSA
Little Miss BSA Offline
Diamond Poster
Little Miss BSA
Joined: May 2007
Posts: 1,185
Miami
Oh and by the way - these accounts should most definitely be classified as PEPs
_________________________
"Never allow someone to be your priority while allowing yourself to be their option!"

Return to Top
#958433 - 05/13/08 06:32 PM Re: Mexican Consulent Business Little Miss BSA
John Burnett Offline
10K Club
John Burnett
Joined: Oct 2000
Posts: 39,684
Cape Cod
Or, we could be going in the wrong direction. A consulate doesn't usually operate businesses. I'm guessing "consultant" or "consultancy" is where crazed is going.
_________________________
John S. Burnett
BankersOnline.com
Fighting for Compliance since 1976
Bankers' Threads User #8

Return to Top
#958450 - 05/13/08 06:44 PM Re: Mexican Consulent Business Little Miss BSA
crazed Offline
Member
Joined: Dec 2005
Posts: 61
Sorry, I do mean consulant. I guess the instructions are there for a reason. I was taken off guard when I seen a CTR had to be completed.

Can you explain the classification of a PEP? I know this stands for politically exposed persons. What are the requirments of a financial instituion that has accounts classified as a PEP?

Return to Top

Moderator:  Andy_Z