First, look to your bank's CIP and how it addresses businesses with authorized signers. Does it call for subjecting signers to the process? Then figure out what your policy says about identifying non-present individuals. Do you have procedures for verifying identity for service members who are deployed overseas? Perhaps with some minor tweaks, you can assemble a procedure for this situation.
First published on BankersOnline.com 9/5/11
How to Conduct CIP on a Person Abroad
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Question:
We have a new business customer who is opening an account with two signers. One is a local person, the other is abroad permanently. What would be the proper way to conduct CIP on a person abroad?
Answer: