Not a perfect solution, but we add an alert message at the CIF level stating that if they open an account we need to do full CIP and Beneficial Owner.

Amy M. Barone
Vice President
Director of Operations
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________________________________

From: Kathy Yeggle <xxxxxx@YourCovenantBank.com>
Date: February 26, 2019 at 6:22:08 PM EST
To: xxxxxx@simplelists.com <xxxxxx@simplelists.com>
Cc: Paul Shearer <xxxxxx@YourCovenantBank.com>
Subject: SilverLake MA-RUG JH CIFs & Beneficial Ownership

CAUTION! - The content below originated from outside the Five Star Bank network.

________________________________

I am wondering if anyone else has the same situation and how you are handling it.

We have the following- a business holding an escrow account for another business.  We know that we are required to get beneficial ownership on the business that is the escrow agent.

We create a CIF for both entities,  if we don't get beneficial ownership for the business that is the escrow beneficiary,  they show on the exception report.  If we exclude them,  I'm afraid that it will be missed if they open their own account at a later date.

Has anyone run into this?

Kathy Yeggle
Vice President
BSA Officer & Compliance Manager

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