Company's business license-expired or revoked

Posted By: Victoria S

Company's business license-expired or revoked - 02/29/16 05:19 PM

Scenario: ABC Roofing maintains 2 business accounts. Bank recently discovered business licenses have been revoked.

What is the proper course of action? Insist the account be closed?

Please advise.

Thanks.
Posted By: rlcarey

Re: Company's business license-expired or revoked - 02/29/16 05:46 PM

I would make an inquiry to the company and give them xx days to provide proof that they are again licensed prior to accepting additional transactions. This is not really a BSA/AML issue, more of a reputational risk avoidance practice now that you know.
Posted By: Pat Patriot Act

Re: Company's business license-expired or revoked - 02/29/16 05:50 PM

I agree with rlcarey here - notify the customer to have them update the documentation. It's not directly a BSA compliance issue in 2016 unless you've exempted them, but it may be in 2018 when the CDD NPRM most likely goes into effect.
Posted By: edAudit

Re: Company's business license-expired or revoked - 02/29/16 05:51 PM

agreed with the above but will like to add

It's not directly a BSA compliance issue until the CMP show up.
Posted By: Victoria S

Re: Company's business license-expired or revoked - 02/29/16 06:27 PM

Appreciate your input.