Answer:
Answer by Andy Zavoina:
My read from the preamble is that those addresses are not sufficient as the only address. A physical address is what is desired and there are few exceptions allowed.
Pg. 31 of the PDF version: Treasury and the Agencies believe that the identification, verification, and recordkeeping provisions of the Act, taken together, should provide appropriate resources for law enforcement agencies to investigate money laundering and terrorist financing. The final rule therefore provides that a bank generally must obtain a residential or business street address for a customer who is an individual because Treasury and the Agencies have determined that law enforcement agencies should be able to contact an individual customer at a physical location, rather than solely through a mailing address. Treasury and the Agencies recognize that this provision may be impracticable for members of the military who cannot readily provide a physical address, and other individuals who do not have a physical address but who reliably can be contacted. Accordingly, the final rule provides an exception under these circumstances that allows a bank to obtain an Army Post Office or Fleet Post Office box number, or the residential or business street address of next of kin or of another contact individual. For a customer other than an individual, such as a corporation, partnership, or trust, the bank may obtain the address of the principal place of business, local office, or other physical location of the customer. Of course, a bank is free to obtain additional addresses from the customer, such as the customer’s mailing address, to meet its own or its customer’s business needs.
Answer:
Answer by Ken Golliher:
Agreed. For an individual, an acceptable address must be the individual's business or residential street address. Clearly, I do not live there and Mail Boxes Etc. is not my business address unless it is where I work.
An individual who does not have a residential or street address may use a military address or the residential or street address of a next of kin or contact individual. Neither "my next of kin" nor my "other contact individual" lives at Mail Boxes Etc. either, so those alternatives do not work.
Many banks keep lists of these entities or rely on the use of reverse directories to unearth customer use of these mail drops.
Answer:
Answer by Lucy Griffin:
To illustrate what Andy and Ken are saying, I'll share two stories. First, federal marshals have been known to raid Mail Boxes only to discover that their suspect wasn't working there. The "office" was elsewhere.
Second, I was visiting my Mail Boxes (now UPS Store) once when two men (who frankly looked quite a bit like terrorists and angry ones at that) were vociferously protesting with the owner of the store that the person they were seeking had to be here because this was his address. Obviously, the person they were seeking did not want to be confronted by them and had withheld his physical address.
When a customer provides a box number or a suite number, your front line needs to find out what it is. A good way is to ask whether it is an office or an apartment. The answer will usually come back "um, its a mail box." Or ask whether the address is where the business is physically located.
First published on BankersOnline.com 9/8/03
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