Answer:
Regardless of who your primary federal regulator is, you'll find the guidance in the OCC's Compliance Examination Handbook helpful in the section dealing with opening and maintaining accounts. It suggests that in connection with personal accounts you require satisfactory identification, such as a driver's license with a photograph, a U.S. passport, or alien registration card, to open an account. Other acceptable secondary forms of identification include a college photo identification card, a major credit card (verify the current status), an employer identification card, and/or a current utility bill from the customer's present residence (i.e., gas, electricity, telephone).
It says you should also:
Consider the proximity of the customer's residence or place of business to the bank office or branch location. If it is inconvenient, the bank should determine why the customer is opening an account at that location.
Call the customer's residence or place of employment to thank him or her for opening the account. Discovery of disconnected phone service or no record of employment warrant further investigation.
Consider the source of funds used to open the account. Large deposits, especially cash, should be questioned.
For large accounts, ask the customer for a prior bank reference and, if appropriate, write to that bank and request a customer reference.
Consider using:
Thirdparty references, such as credit bureaus, banks, or other references.
Verification services.
Telephone, web site, and reverse directories.
On Business Accounts,
Ask business principals for evidence of legal status (i.e., sole proprietorship, partnership, or incorporation or association).
Determine who are the beneficial owners of all accounts in private banking, trust, and other specialized banking departments. The bank should pay particular attention to corporate entities, international business corporations, bearer share companies, or nominee officers, especially if such organizations are based in countries or jurisdictions considered to be secrecy or money laundering havens.
Check the name of a commercial enterprise with an informationreporting agency and check prior bank references.
Call the customer's business to thank him or her for opening the account. Disconnected phone service warrants further investigation.
If appropriate, visit the customer's business to verify its existence and its ability to engage in the business it described.
Require satisfactory identification for all subaccount holders for payable through accounts with foreign banks.
Consider the source of funds used to open the account. Large deposits, especially cash, should be questioned.
Consider obtaining a:
Financial statement.
Description of the customer's principal line of business.
Description of the customer's primary trade area, and whether international transactions are expected to be routine.
Description of the business operations, the anticipated volume of cash and total sales, and a list of major customers and suppliers.
Thirdparty reference, such as a credit report, Dun & Bradstreet report, or Lexus/Nexus information.
Verification service.
Telephone, web site, and reverse directories.
First published on BankersOnline.com 5/07/01
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