Large Bank Supervision Forum eBook

Internal Use Only

Customer Due Diligence . . .

Customer Information Program: Enables the bank to form a reasonable belief of customer identity Program must be written: • Account opening procedures • Customer identification and verification methods

CIP

BO

CDD

105

© 2023 – FinPro, Inc.

Internal Use Only

Customer Due Diligence . . .

Beneficial Ownership: 1. Required to have written procedures 2. Must identify all beneficial owners of legal entity

CIP

BO

customers (C-corp, LLC, etc) • 25% or more ownership • Single individual who controls, manages, or directs • Can rely on info provided by person opening the account • New accounts opened after May 11, 2018 • Existing accounts when aware of updated info

3. Key Points

CDD

106

© 2023 – FinPro, Inc.