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Beneficial Ownership Rule- Escrow Account

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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.

We would need more information for this unusual situation to determine who actually is the accountholder.

First published on 12/22/2019

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