Regulatory Alerts2010-03-05
Added
Guidance on Obtaining and Retaining Beneficial Ownership Information
The Financial Crimes Enforcement Network and other federal agencies clarify regulatory expectations for financial institutions to obtain and retain beneficial ownership information as part of Customer Due Diligence programs. Covered institutions must implement risk-based procedures to identify and verify beneficial owners of legal entities, trusts, and private banking accounts, applying Enhanced Due Diligence to high-risk relationships. Specific requirements include ascertaining the source of wealth for private banking accounts with minimum deposits of $1,000,000, identifying owners of non-publicly traded foreign banks, and prohibiting correspondent accounts for foreign shell banks.
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