Answer:
For the purposes of the recordkeeping requirements of section 103.29 of 31 CFR Part 103, the individual conducting the transaction (the one at the teller window) is the purchaser, regardless of the person for whom he is purchasing the check. If the purchaser does not have a deposit account with you, you must collect and record the additional personal information required, based on his status as a non-depositor. Note that account relationships other than deposit account ownership don't qualify. For example, authority as an authorized signer on a deposit account, status as a borrower, rental of a safe deposit box or status as a trust customer or client of your investment department don't qualify the individual as having a deposit account, and you'd have to collect the extra information.
First published on BankersOnline.com 7/06/09
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