We have had some questions come up about the W-8BEN form and now we are trying to figure out if our procedures are correct or not.

When opening an account our questions would go something like this:

Do you have a US Taxpayer ID number: Yes or No (If no....we do not open any account).
If Yes: Are you a US citizen: yes or no
If No: Are you a resident alien: yes or no
If No: Execute for W8-BEN

However, we do not open interest bearing accounts for non-resident aliens.

SO....is a W8-BEN even required if we are not opening an interest bearing account?

Somewhere along the line the FFIEC Exam Procedures decided to make a reference to the W8-BEN in the non-resident alien section as a possible option for due diligence on a potentially higher-risk customer type because knowing the country of citizenship can help an institution understand the customer's risk profile better, particularly if the customer engages in international transfers. However, this is an IRS document, not an AML/CFT document. You can get the same information by having a question on a CDD form:

If Yes: Are you a US citizen: yes or no
If No: Are you a resident alien: yes or no
If No: Please state your country of citizenship

There is no requirement and no value to having a W-8-BEN on a non-interest bearing account.

Thank you Brian! This will make it much easier on our account reps as this was always very confusing to everyone.

I appreciate the help!