Thread Starter: Anonymous
Title: Re: Weird examiner question on Beneficial Ownership
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Examiners can ask some pretty weird things sometimes. It's important to remember that asking a bank for something doesn't create a requirement for the bank to have it or do that action. Here are the questions that I was asked today:
Are your beneficial owners checked against OFAC?
Are they checked when you perform a 314(a) records search?
(In other words: when you collect beneficial ownership data on a paper form, and some of the individuals who are beneficial owners are not customers in any sense and their only connection to your bank in any way is that they are the ultimate beneficial owners of an LLC or corporation which is your customer, do you then create a customer record for those beneficial owners, so that your system will check their names automatically every time you do an OFAC search and every time you run 314(a) twice a month?)
I'm thinking: who said we need to be doing that in the first place? Let's say I had an exact OFAC match on a beneficial owner on a new account. Would that be enough to cause me to have to take action?
Let's say I had a 314(a) match on a non-customer who was only a beneficial owner of a customer. Would 314(a) require me to respond to that a positive match?
I rather doubt it.
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