Will the Beneficial Ownership Rule Require Updates to the USA Patriot Act Notice?

The Bank Secrecy Act requires financial institutions to provide a notice about procedures for opening a new account. The USA Patriot Act notice can be posted in the financial institution’s lobby and reads:

Important Information About Procedures for Opening a New Account

To help the government fight the funding of terrorism and money laundering activities, Federal law requires all financial institutions to obtain, verify, and record information that identifies each person who opens an account.

What this means for you: When you open an account, we will ask for your name, address, date of birth, and other information that will allow us to identify you. We may also ask to see your driver’s license or other identifying documents.

Financial institutions are asking if the Bank Secrecy Act requires this posted notice be amended in light of the upcoming requirements of the beneficial ownership rule. The answer is no. We do not see anything in the beneficial ownership rules that require financial institutions to change the notice. However, some financial institutions may decide for service reasons to notify people opening business accounts about why new information is being asked at account opening.

CLA’s BSA/AML compliance services  cover BSA, AML, OFAC, and CIP requirements applicable to the USA Patriot Act, customer due diligence , as well as other areas. Please contact me for more information.

CLA’s financial institution regulatory compliance team assists banks and credit unions nationwide in establishing regulatory compliance programs, conducting compliance testing, and training staff on regulations. Justin Robinson is a member of CLA’s regulatory compliance team and can be reached at justin.robinson@CLAconnect.com.

Comments are closed.