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Identification of Totten Trust Beneficiaries

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Under the USA PATRIOT Act regulations and upcoming CIP, do we need to have photocopies of the driver's license and/or social security numbers for beneficiaries on a Totten Trust? In most cases, we never see the beneficiaries, as they are not signers on the account. Also, do we have to check them on OFAC?

Beneficiaries do not meet the definition of "customer," you are not required to run them through your CIP program's methods for verifying identity.

You are not required to check anyone against the OFAC list. It is entirely a risk weighted decision. You are to evaluate the likelihood of a positive response against the effort in conducting the verification.

However, if Fidel Castro is the POD beneficiary on my time deposit, he currently has no interest in the account and the OFAC sanctions could not attach. So, your most likely answer is, "No."

First published on 07/07/03

First published on 07/07/2003

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