Embassy Account

Posted By: Calmeida12

Embassy Account - 04/09/15 02:32 PM

Does anyone know what legal documents are required to open an account for an embassy? For example for an LLC, you need the Articles, LLC agreement, etc. Also, what type od enhanced due diligence do you perform? Thank you.
Posted By: el guapo

Re: Embassy Account - 04/09/15 04:45 PM

I hope this question is being asked in advance of changing your policy to allow for the opening of these accounts in the future, rather than after having committed to opening this type of account with no policy in place (or worse, a policy that forbids opening this type of account which you will now be ignoring).
Posted By: ACBbank

Re: Embassy Account - 04/09/15 05:18 PM

FinCen opined on this topic back in 2011.

http://www.fincen.gov/statutes_regs/guidance/pdf/FFIEC_FinCEN_24_march.pdf
Posted By: Calmeida12

Re: Embassy Account - 04/09/15 05:37 PM

I have gathered all the necessary items for the due diligence in advance for future need and to be included in a future policy revision. I just don't know what legal documents to mention in the policy and the correct wording necessary to title such an account. As for other entity types, I list in the policy the required documents such as Articles, LLC Agreement, etc. and samples of how to title the accounts. Thank you.
Posted By: edAudit

Re: Embassy Account - 04/09/15 06:07 PM

there is a lot of potential bsa risk whoy would you wish to open one here and there? Leave it to the private banking guys.

Prior to PEPS being an issue in a prior bank they thought it was a good idea until PEPs became an issue and it was dropped as fast as they could.

If the future is for a substantial amount of theses that would be a different story.
Posted By: BrianC

Re: Embassy Account - 04/09/15 08:03 PM

Ken Golliher once called this the "deep end of the pool."

http://www.bankersonline.com/forum/ubbth...rue#Post1581495