Policy for Customers that are not US Citizens

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Question:

We have a few customers that are non-US persons residing outside the US. They were added to accounts while here visiting relatives, etc. If the VISA and/or Passport expire, should we require updated, non-expired information? What if they do not plan on re-entering the US for a while? It is how we identified our customer originally, but if they are not planning to travel, are they expected to maintain current documents?

Answer:

Answer by Brian Crow: Let's first consider a US Citizen who opens an account using a driver's license, signs up for direct deposit and internet banking, and never enters your bank again. It is unlikely that you would be contacting this individual in a few years to make sure that they have renewed their driver's license, so there is no need to reach out to a non US-citizen for this either. However, in the event that the individual is earning interest on any of the accounts, you will need to certify their foreign status and obtain an updated W-8BEN form every three years.

Answer:

Answer by Ken Golliher: Once you have established a reasonable belief regarding someone's identity that does not change because the documents you used to do it have expired.

First published on BankersOnline.com 12/12/11