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CIP for Foreign Private Investment Companies

We have been getting a lot of Foreign Private Investment Companies opening accounts at our bank. We are struggling with the address verifications for them.What type of documents are used to verify addresses? Would a letter from an attorney or accountant from the country that would state the PICs' address suffice? Would the address shown on the articles suffice?

Answer by Randy Carey:If you don't have an experienced international department, my first question would be why are they at your bank? If you do have an experiencd international department, they already should have the tools to vet international companies, including the proper contacts with officials in the countries in which they are registered.


Answer by Kathleen Blanchard:PICs have formation documents. Your bank should not be opening these accounts without already having done its CIP and BSA/OFAC risk assessments on this type of entity. You need to fully understand the entities, how they are formed, the laws of the countries where they are located and all of the risks presented.

Blindly taking these customers on and then determining how to handle them is putting the cart before the horse. I would at least put a temporary halt to this until the proper risk assessments are completed and decisions on acceptance, CIP, etc. are made.

First published on 1/18/10

First published on 01/18/2010

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