Thread Starter: Anonymous
Title: Re: Business Accounts Beneficial Owners
|
Our organization is opening business accounts on a consumer platform and can’t always “fit” all the beneficial owners of the business in the account owner cells. Since we can’t search other fields for OFAC, 314(a), and BSA issues, we have told the customer contact folks that any business with more than 3 owners need to take their business elsewhere. We hate turning business away and are facing increasing pressures to find some flexibility here.
It is our understanding that we need to have a reasonable knowledge of our “customer” in order to comply with the spirit of the BSA and related regulations. As such, we need to know many things about each business, including who are the “owners” of the company in question. If we have 4 owners of a business and only 2 are authorized to transact on the account, are we in compliance if we only monitor the entity name and the two authorized users? We say no since we unable to reasonably search for these beneficiaries on the various registries and we can’t aggregate their cash transactions properly if we don’t assign them a unique identifier (i.e. SSN).
Can you advise what your organizations are doing? Are you searching ALL beneficial owners or only the ones authorized for the account?
|
|
|
|
