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BSA/CIP Control Prong Requirements

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Question: 
I have a branch that is telling me that a business that is opening an account is syndicated and set-up for tax credit reasons. This is a rather large country-wide real estate developer and I have no information that excludes this type of entity from either the beneficial ownership or control prong requirements. They appear, to me, as just a for profit business as any other. Am I correct in thinking that both prongs apply and no exemptions apply.
Answer: 

Yes

First published on 07/08/2018

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