Q: If an individual named as a beneficial owner of a new legal entity account is an existing customer of the covered financial institution subject to the financial institution’s CIP, is the bank still required to identify and verify the identity of this individual or may it rely on the CIP verification of the individual that it previously performed?
A: In general, banks must identify and verify the identity of beneficial owners of their legal entity customer at the time of account opening. If the beneficial owner, however, is an existing customer of the bank who is subject to the bank’s CIP then the bank may rely on information in its possession to fulfill the CIP identification and verification requirements, provided that the existing information in the bank’s possession is up-to-date, accurate, and the legal entity customer’s representative certifies the accuracy of the pre-existing CIP information either verbally or in writing.
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