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Verifying Ownership under the New CDD Regulation

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Question: 
How do we verify that the beneficial owner actually holds a 25% ownership interest in the corporation opening an account at our bank?
Answer: 

Unless the corporation is publicly traded and listed on a major exchange, you probably cannot. In the U.S., corporations are established at the state level. According to a 2014 survey conducted by the National Association of Secretaries of State, state agencies very rarely require the disclosure of ownership information by legal entities, either at the time of formation or in their periodic reports.
However, the new CDD regulation does not require you to verify ownership.

Unless you have reason to believe the information provided by the individual opening the account is not accurate, you are entitled to rely on their certification as to whether the individual named is an owner and owns enough of an interest to qualify as a beneficial owner. Your only responsibility is to verify the existence of the individuals who are identified to you as beneficial owners.

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Learn more about Ken’s webinar Customer Due Diligence! New BSA Regulation

First published on 06/05/2016

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