As it pertains to the Beneficial Ownership Rule, we have a municipality that wants to open an escrow account for a business. The business is an LLC, but
the municipality is in charge of the funds. For BSA purposes, do we need to obtain all the normal documents for the LLC including all info on owners?
How in depth do we need to dig for this? In this case the LLC is not an existing customer of the bank.
What are the legal requirements for a bank to open a savings account for an individual customer? From what I understand, banks usually require (1) a signature card and (2) the following identity information: name, address, date of birth and identification number. I don't need any clarification on the identity requirements for Know Your Customer compliance. I am looking for more clarification on the requirements for the signature card. Is the signature card required by law to open a bank deposit account? If so, what is the law and what is the legal definition of a signature card (e.g. the required elements for a signature card)?
What risk does our bank take when accepting a large check payable to a non-customer corporation and an individual (our customer) and our customer wants to deposit the check into their personal account? If the check has a signature guarantee from the corporation's bank, is our bank at any type of risk for accepting this check for deposit into our customer's personal account? Should we recommend that the check be deposited into the corporation's bank account and the corporation write a check to the individual?
For many of the ABA/ABA Anti Money Laundering Conferences, Rick Small, formerly from the Federal Reserve Board of Governors and now Citigroup's Global AML Director, presented a good natured "TopTen
The full meaning of the Patriot Act is starting to become very clear to many members of the financial community. In the minds of many, including those in the U.S.
There seems to be some confusion at our bank concerning depositing third party checks into a customer's account when the check being deposited is not made payable to the account holder. I could think of very many issues surrounding this such as potential fraud and liability issues; however, am unaware of any laws (such as UCC) which would regulate this.
We have a customer that has existing accounts with the bank and when he comes into the bank he harasses (verbally upsets) the tellers, CSRs, etc. Recently he has mailed a copy of his customer ID, and checks to open another deposit account with our bank. I realize the BSA Know Your Customer Guidelines. Do we have to open the account? Can we close his other accounts, including an IOLTA because of his behavior with our personnel?
Question: I know that under the terms of the USA PATRIOT Act we're supposed to have a CIP - a Customer Identification Policy.
If I have a check with 2 payees with "and" separating them, and both have seemingly endorsed the back, should the check be deposited into a joint account or is an individual account okay?