Questions and Answers
What is required under CIP for opening an account for a legal entity such as a corporation when it comes to the individual signers? Do we need to collect social security numbers, date of birth, and driver's licenses, home address, etc. on each signer?
For CIP purposes, the corporation is the account owner, not those with signing authority on the account. Therefore, you will need to collect the corporation’s name, employer identification number and address. There is no requirement that you collect any information on the account signers. However, if you cannot form a reasonable belief that you know the true identity of the corporation or the corporation presents a heightened risk of money laundering activity, you may apply your CIP to the account signers. Your CIP should include provisions for dealing with this type of situation.
(Posted: 01/24/2008)
