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LEIs or not?

Question: 
What is an LEI? Do we have to use it to establish beneficial ownership certification?
Answer: 

The Legal Entity Identifier (LEI) is a 20-character, alpha-numeric code, to uniquely identify legally distinct entities that engage in financial transactions.

The Regulatory Oversight Committee (ROC) is a group of 71 public authorities with full membership and 19 observers from more than 50 countries established in January 2013 to coordinate and oversee a worldwide framework of legal entity identification, the Global LEI System.

It is an optional field on the beneficial ownership certification form in the Bank Secrecy Act appendix. You only use it if your entity has an LEI and your financial institution’s procedures ask for it. Do not use the field for obtaining charter numbers or NAICS codes those are different numbers and may be important but are not required on the beneficial ownership form in the appendix of the Bank Secrecy Act.
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Learn more about Deborah Crawford’s webinar
Opening Business Deposit Accounts-CIP and Beneficial Ownership

First published on 07/22/2018

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