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#1896070 - 02/11/14 08:40 PM Business accounts
Calmeida12 Offline
100 Club
Joined: Sep 2012
Posts: 249
I'm revising new account procedures for business entities and was wondering what other banks collect:
For example:
ABC Inc has 2 Officers/Directors as per Secretary of State website and documentation.
Both Officers will sign the Corporate Resolution but only one will be an authorized signer in the account.
My question is: Do you create a CIF record for both and list one as principal and the other as principal/authorized signer and collect CIP for both?

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BSA/AML/CIP/OFAC Forum
#1896103 - 02/11/14 09:26 PM Re: Business accounts Calmeida12
MrsSmithCRCM Offline
100 Club
MrsSmithCRCM
Joined: Dec 2012
Posts: 169
Here for the moment
Depends on your FI policy and procedures. We only do full CIP on authorized signers. Any other director/officer information is retained in the customer file, and should match articles of incorp. etc. or resolution, etc. but we do not CIP non-signers. If at any time they become signers, want information, etc, full CIP is done before transactions are processed or accepted.

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#1896110 - 02/11/14 09:34 PM Re: Business accounts Calmeida12
Calmeida12 Offline
100 Club
Joined: Sep 2012
Posts: 249
So how do you check for ongoing OFAC and 314(a)on officers/directors?

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#1896115 - 02/11/14 09:39 PM Re: Business accounts MrsSmithCRCM
SunnyFL, CRCM Offline
100 Club
Joined: Sep 2004
Posts: 205
FL
We do the same as New2Comply. No need to muddy the CIF files with non-signers. If at any time signers change, we start again with CIP on the signers, new resolution, signature card etc.

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#1896364 - 02/12/14 04:36 PM Re: Business accounts Calmeida12
Calmeida12 Offline
100 Club
Joined: Sep 2012
Posts: 249
Do you apply the same procedures for a foreign business entity? Meaning what happens if one of the Officers/Directors is a foreign national and he won't be a signer on the account, do you CIP them?

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#1896449 - 02/12/14 06:10 PM Re: Business accounts Calmeida12
SunnyFL, CRCM Offline
100 Club
Joined: Sep 2004
Posts: 205
FL
We do not do an OFAC check on officers/directors - unless they are signers on the account. Even that is not a requirement of CIP because the entity is actually your "customer". We have written our procedures to include applying customer identification requirements to all signers of clubs, businesses and organizations. And then of course you have your risk assessment to back up your procedures. If you can justify not having a need and it is not required than why do it. Your CIP may be written differently or your risk may be higher.

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#1896492 - 02/12/14 06:47 PM Re: Business accounts Calmeida12
rlcarey Offline
10K Club
rlcarey
Joined: Jul 2001
Posts: 83,396
Galveston, TX
And your CDD and EDD requirements may go further than your CIP requirement, specifically if you are dealing with off-shore companies.

If you are asking these questions, you probably don't bank off-shore companies on a regular basis and as such, my question is why would you want to develop all the required policies and procedures necessary to actively manage off-shore customers for one or two of them.

Do both of you a favor - send them to a bank that has an international banking department.
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The opinions expressed here should not be construed to be those of my employer: PPDocs.com

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