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#2139863 - 07/27/17 11:35 PM Verifying Ownership Percentage
Mel in WA Offline
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Joined: Mar 2013
Posts: 1,266
Under the beneficial ownership requirements, is the bank required to verify/confirm ownership percentage by obtaining documentation that supports what the customer is certifying (i.e. shares, etc.)?

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BSA/AML/CIP/OFAC Forum
#2139868 - 07/28/17 12:23 AM Re: Verifying Ownership Percentage Mel in WA
rlcarey Offline
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rlcarey
Joined: Jul 2001
Posts: 83,396
Galveston, TX
Just what would you proposed to get to do that verification?
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#2139880 - 07/28/17 11:25 AM Re: Verifying Ownership Percentage rlcarey
edAudit Offline
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edAudit
Joined: Jul 2008
Posts: 4,797
You are here
Originally Posted By rlcarey
Just what would you proposed to get to do that verification?


A headache
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#2139895 - 07/28/17 01:00 PM Re: Verifying Ownership Percentage Mel in WA
Elwood P. Dowd Offline
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Elwood P. Dowd
Joined: Aug 2001
Posts: 21,939
Next to Harvey
Although not required, asking for the percentage of ownership is a reasonable thing to do in connection with checking the OFAC list.

Attempting to "verify" what you are told is a fool's errand; there is no way to do it without relying on documentation which the legal entity customer's representatives could not easily fabricate. If they are going to lie to you, they will have no qualms about generating documentation in support of the lie.

Don't try to fix a regulation that was badly done...
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