Q3 policy questions

Acme Bank · started today, 9:40 AM

MB

You

Does our CDD timing policy still hold for beneficial owners when the customer is a trust? Acme flagged two accounts opened last week.

H

Hickory

FinCEN requires beneficial ownership information to be collected at account opening, and the AML Policy v4.2 keeps the 30-day CDD window only for the legal-entity customer itself, not the beneficial owners [1][2]. For the two trust accounts, the trustee counts as the beneficial owner for control purposes, so collection was due at opening. I have started an OFAC screen on both so you have the results before the review.

OFAC screen · Customer ZedRunningStep 2 of 4 · Screening 2 parties · started 2 min ago
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