Thread Starter: Anonymous
Title: Re: OFAC for Authorized Signers
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I am part of a publicly traded company that manages over 1,000 DDA accounts at over 250 banks in the US. For various reasons we are re-organizing our bank accounts to fit a new operating model. In some cases we are opening new accounts with existing banks and in other cases we are beginning new banking relationships. In many cases we are being asked to provide the SS# and driver's license information for the authorized signers on the business accounts we're opening. I am completely in tune with the banks need to comply with the BSA and with their own internal CIP policies. However, we also have a responsibility to our employees to protect their personal information. In most cases, we are able to supply certain organizational documents that allow a bank to waive the requested personal documents/information from our employees. I have one bank that insists that OFAC rules require the bank to obtain the driver's license of our employees to run an OFAC check. I can find nothing that provides any guidance to us on the actual OFAC requirements for corporations, publicly traded companies, etc. I suspect the requirement the bank is referencing is part of the bank's internal OFAC Program but it is not specifically required as part of the reg. Can anyone direct me to any guidance on this topic? Thanks in advance.
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