We use a vendor's product for CIP purposes at the bank. When running a sole proprietor account, is there a reason we should be doing the full search or is OFAC alone sufficient? The same would go for unregistered organizations.
Can we open a personal account and label it “Farm Account” and let the customer operate a business out of it?
Our signature is asking for an exempt code in the W-9 portion of the contract. What is it and where are the codes?
If the business is sold can the new company keep the account and TIN?
What is a shell company?
Two non-customers came into the branch. Each has a check payable to themselves for $6,000 from the same attorney. They go to the teller window together and each person cashes their check. They are together at the window the entire time. Does a CTR need to be filed because they were conducting the transactions together?
Does a foreign business have the same tax structures as the US?
A customer of ours came into the bank and cashed six checks totaling $29K. Some were drawn off of our bank and some were not. When I file the CTR, what account number should I use in Part I, item 22?
Should I use the account numbers from each check that was cashed?
Should I use the account number of our customer even though none of the checks that were cashed came from her account?
Should I leave Item 22 blank?
I need clarification on the beneficial ownership rule. If we have non-profit or charity accounts that are not legal entities, do we have to do the control prong? What if their paperwork does not have them classified as a corporation or LLC but they have a separate EIN? Do we then do the control prong? And what if the account is very old and they don't have the actual papers stating if they are incorporated, etc. but have a separate EIN? Does the EIN make a difference?
Can a BSA violation cost $528,000,000?