NEW ACCOUNT INTERVIEW CHECKLIST (BUSINESS/NON-PROFIT/CHARITIES) Business, Non-Profit, & Charities Account Information Sheet

Transcription

1 NEW ACCOUNT INTERVIEW CHECKLIST (BUSINESS/NON-PROFIT/CHARITIES) Business, Non-Profit, & Charities Account Information Sheet Corporation (For Profit) Partnership (General) Partnership (Limited) FOR BANK USE: Non-Profit Corporation) Non-Profit Organization Unincorporated Limited Liability Company Limited Liability Partnership Sole Proprietorship Attorney Client Trust Other: NUMBER OF SIGNATURES REQUIRED Port: Acct. No.# Product Type: Business Account Name: Tax ID #: Business Physical Address: Statement Address: Business Phone Number: Type of Business: Authorized Signers/Titles: The Unlawful Internet Gambling Enforcement Act (UIGEA) prohibits any person engaged in the business of betting or wagering from knowingly accepting payments in connection with the participation of another person in Unlawful Internet Gambling. I certify that the business named below does not engage in an Internet gambling business: Business Name X Authorized Signer Date 1. Name: SSN: Physical Home Address: City, State, Zip: Home Phone: Employer: Occupation: Work Phone: Birth Date: Birth Place: Mother s Maiden Name: D/L #: Expiration Date: Issue Date: State Issued Form BSA-6 (Revised ) Page 1 of 7

2 ADDITIONAL VERIFICATION STEPS, IF ANY: Follow-up Contact (Describe): ChexSystems Verification: Reference Verification: Account Opened Date: Discrepancy Resolution, if any: Verification Against Government Issued List: Resolution: Power of Attorney ANTICIPATED BANK ACTIVITY (Estimate monthly volume for all accounts) Month Total $ Cash Inflow (deposits) Cash Outflow (withdrawals) Checks Inflow (deposits) Checks Outflow (checks written) Wire-Domestic Inflow (received) Wire-Domestic Outflow (sent) Wire-Foreign Inflow (received) Wire-Foreign Outflow (sent) ATM/Debit Card Inflow ATM/Debit Card Outflow ACH /Online Banking/Bill Pay Deposits Inflow ACH /Online Banking/Bill Pay Deposits Outflow Int'l ACH Inflow Int'l ACH Outflow Cashier's Checks Monthly # transactions Largest Single Transaction $ Does the business provide any of the following Services: Yes No ATM Personal or Leased. Refer to Compliance Officer **Does the business provide any of the following services: check cashing money orders /travelers Checks wire transfers/funds Transfers Seller, issuer or redeemer of Prepaid Access Cards (Check all that apply) Money Service Business must be registered. Refer to Compliance Officer *UIGEA Is the customer engaged in an Internet Gambling Business? Refer to Compliance Officer * If the business does engage in Internet Gambling Business, the account can not be opened without evidence of legal authority to engage in the internet gambling business and approval from the Compliance Officer. NOTE: If the nature of the business is one of the following, it is considered a Higher Risk Account (check all that apply): Currency exchange houses Money transmitters Check Cashing facilities* Casinos/card club operator Leather goods store Offshore corporations Travel Agency Auctioneer Car, boat, airplane dealerships Manufacturer Broker/Dealer Import/Export Jewel, gem, metal dealer Ship,bus,plane operator Pawn broker Telemarketer Restaurant Convenience Stores Transportation Retail Store Investment banker Parking Garage Legal Service Providers (Lawyers) Accounting Services Deposit broker *Check cashing facilities can include convenience/grocery stores that routinely cash checks for customers that may exceed $1,000 per day to any one person. Check cashing facilities must be registered with Treasury Dept (FinCEN)and show proof I certify that I have personally received the information for each of the above signatories, have accurately recorded the details from each of the identifications, and completed the attached CIP Risk Analysis Worksheet. Account signatories are required to complete individual identification verification form. Information Verified By: Name & Title Date: Form BSA-6 (Revised ) Page 2 of 7

3 CIP RISK ANALYSIS WORKSHEET Account Name: Account No: Definition for Level of Risk: Minimal Risk Average Risk Moderate Risk High Risk Very High Risk and above Customer: Type Level of Risk - If Applies New Customer 2 Existing Customer 1 Customer Categories: Information Level of Risk - If Applies Non-Resident Alien 9 Non-Local Address 3 Business with Multiple Locations 3 Other Businesses defined as High Risk on prior page (with exception of Cash Intensive and Money Service Business (MSB) 5 Cash Intensive Business ** 15 Money Service Business** 20 ** For all accounts classified as Cash Intensive Business (i.e. convenience stores, liquor stores, restaurants, retail stores, privately owned or leased ATMs, vending machine operators, jewelry stores, parking garages, casino and card clubs) and Money Service Business (MSB s) the following sections do not need to be completed. Input the risk rating of 15 or 20. A Money Services Business can not be opened without the approval of the Compliance Officer or Senior Management. Personal Accounts/Deposit Products: Account Type Level of Risk - If Applies Transaction Account 2 Non-Transaction Account (i.e. Savings, CDs, IRA) 1 Non-Personal Accounts-Deposit Products Account Type Level of Risk - If Applies Transaction Account 2 Non-Transaction Account (i.e. Savings, COD) 1 Non-Person Organization Types Organization Type Add to Risk - If Applies Factor Corporations 2 Partnerships (General) 2 Partnerships (Limited) 3 LLC s 2 Non-Profits 3 Lodge/Associations 3 Sole Proprietor 2 Risk Rating Score: (Total of Levels of Risk indicated above) LOW RISK 2-5 MEDIUM RISK 6-10 HIGH RISK 11 or more Accounts risk rated 11, 12, 15 and 20 will be monitored quarterly, semi-annually or annually as determined by the BSA Officer. NOTE: If this account is considered a High Risk or Automatic High Risk Account you must continue to the next page and Complete the Enhanced Due Diligence (EDD). If account is an Non government Organization (NGO) such as a non profit, complete the attached form for NGO s. Notification of High Risk Account Status to BSA Officer Form BSA-6 (Revised ) Page 3 of 7

4 ENHANCED DUE DILIGENCE PROCEDURES FOR BUSINESS ACCOUNTS RATED HIGH RISK The basic principal of our Customer Identification Program is that we must be able to form a reasonable belief that we know the true identity of our customers. Therefore, documentary verification must be supplemented by Non-documentary verification measures in instance where the degree of risk is high. For those customers where risk is rated High, perform these additional (non-documentary) verification measures. CUSTOMER S NAME: ACCOUNT NO.: CONTACT THE CUSTOMER AFTER THE ACCOUNT IS OPENED. Follow-up with a telephone call to the customer: Completed on: Completed By: Was the call answer in a professional manner identifying the business? Were you able to speak to the business representative you had met with when opening the account? If no, did you verify a time that you could call back and speak to the business representative? Has there been any change in the level of activity for this business? Additional information regarding the call, list anything that caused you concern, or anything that substantiated the legitimacy of the business: VISIT THE CUSTOMER S PLACE OF BUSINESS (Ask for a tour) Visiting the customer s place of business will verify the actual existence of the business, but you must also consider the businesses physical and human resource capacity, its inventory, security, and locations to verify the legitimacy of the business: Completed on: Completed By: Did the business appear to be adequately staffed to support the stated business purpose of the business? Did the business appear to have adequate inventory (if applicable) to support the stated business purpose? Did the business location appear appropriate based on the stated business purpose? Additional information regarding the visit, list anything that caused you concern, or anything that substantiated the legitimacy of the business: COMPLETE THE HIGH RISK ACCOUNT ANALYSIS FORM (Attachment A of the Bank Secrecy Act Program Policy and Procedures) and forward to the BSA Officer). Form BSA-6 (Revised ) Page 4 of 7

5 ENHANCED DUE DILIGENCE FOR NON-PROFIT ORGANIZATIONS AND CHARITIES Known as Non-Governmental Organization (NGO s) NGO Risk Factors Because NGOs can be used to obtain funds for charitable organizations, the flow of funds both into and out of the NGO can be complex, making them susceptible to abuse by money launderers and terrorists. The U.S. Treasury issued guidelines to assist charities in adopting practices to reduce the risk of terrorist financing or abuse NGO Risk Mitigation To assess the risk of NGO customers, a bank must conduct adequate due diligence on the organization. In addition to required CIP information, due diligence for NGOs must focus on other aspects of the organization as listed below: Account Name: Account Number: Account Address: Contact/Website: ITEM DESCRIPTION/RATIONAL SOURCE OBTAINED Purpose & Objective of Stated Activities: Geographic Location Served (including headquarters and Operational areas: Affiliations with other NGO s, governments, or groups) Donor and Volunteer Base Organization Structure/Charts (intra and inter organizational) Funding and disbursement criteria (including basic beneficiary information) Recordkeeping Requirements: - Solicitation and informational material (If available) Send a copy of this completed form to the Compliance Department. NOTE: For NGO s that are operating or providing services internationally, or lacking proper identification refer to page 48 of Coast National Bank s Bank Secrecy Act Policies and Procedures for further instructions on documentation required for High Risk Accounts. Form BSA-6 (Revised ) Page 5 of 7

6 SOLE PROPRIETORSHIP Current Fictitious Name Statement CORPORATIONS Articles of Incorporation (Signed & Dated) Corporate Resolution (By-Laws & all amended versions) Fictitious Business Name Statement (Current) If Available: Statement of Information Foreign Corporations (Out-of-State) In Addition to above listed items Certification of Qualification to do Business in California GENERAL PARTNERSHIP/PARTNERSHIP (Informal) General Partnership Agreement Partnership Agreement (Informal) LIMITED LIABILITY PARTNERSHIP Certificate of Limited Liability Partnership Agreement Form LLP-1 LIMITED LIABILITY COMPANY (LLC). Articles of Organization Form LLC-1 and Statement of Information LLC-12 (filed Biennially) Operating Agreement Foreign LLC (Out of State) In Addition to above listed items Application for Registration LLC-5 and Certificate of Good Standing NEW BUSINESS ACCOUNT CHECKLIST CURRENT PERSONAL PROFILE FOR EACH SIGNER ON ALL ACCOUNTS (BUSINESS & PERSONAL) Any individual using a name other than his/her legal name must file a Fictitious Business Name Statement with the county Clerk s Office and be stamped approved. Not required if full name is in business title and the business title does not imply other unnamed owners. Articles must be certified by the Secretary of State Minutes authorizing account and signers, certified by the secretary of the corporation, lists corporate officers. Needed only if doing business other than listed on articles, DBA, filed with the County and stamped approved if the Corporation is doing business as anything other than itself. Statement of Information filed annually Documents must be filed with the Secretary of State of California We need the entire General Partnership Agreement We need the entire Partnership Agreement Filed with the Secretary of State of California Filed with the Secretary of State of California Filed with the Secretary of State, issued by State where company was organized (or a declaration certificate not issued by that state) ATTORNEY CLIENT TRUST In addition to documentation based on ownership State Bar EIN State Bar of CA NON-PROFIT ORGANIZATIONS OR CORPORATION By-laws, Charter Copy of group s meeting minutes at which officer s were elected and stating signers for account to be opened Association Resolution IRS Form 501(3)c that shows exemption -non-profit status Non-Profit Corporations-also see Corporations Complete the BSA: Additional Due Diligence form required for Non Profits and Charities (NGO s) May not have if organized as a club Form BSA-6 (Revised ) Page 6 of 7

7 NEW BUSINESS ACCOUNT DOCUMENT CHECKLIST (Page 2 of 2) BUSINESS ACCOUNTS Compliance with the Unlawful Internet Gambling Enforcement Act (UIGEA) Legal Authority to engage in the Internet Gambling Business. Copy of the business account holder s License that expressly authorizes the account holder to engage in the Internet Gambling Business. A written comment by the account holder to notify the Bank of any changes in its legal authority to engage in an Internet gambling business. A third party certification that the business s systems for engaging in the Internet gambling business are reasonably designed to ensure that the Internet gambling business will remain within the licensed or otherwise lawful limits, including with respect to age and location. UIGEA [ Reg. GG or 31 CFR Part 132 as appropriate] Business License issued by the State of California or tribal authority. Form BSA-6 (Revised ) Page 7 of 7