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Enhanced Due Diligence for New Accounts

One of the best ways to avoid being an unknowing accomplice to money launders is to properly identify new customers, when their account is opened. Accordingly, the minimum identification requirements for opening a new account are listed below. If a customer refuses or is unable to provide the requested information within ten (10) business days of opening his or her account, the account should be closed.

Enhanced Due Diligence – Other Factors

  1. New customers are expected to live or work near an office of the institution.
  2. Customer’s that don’t meet the residency requirement will be asked to explain why they choose the particular institution. Failure to provide a sufficient explanation will be grounds for denying the account.
  3. Customers that open a new account with $5,000 or more in cash will be asked to substantiate the legitimacy of the funds. If the customer can’t provide sufficient proof (e.g., a payroll stub, a withdrawal receipt from another bank) the account will not be opened.
  4. Customers that asked to visit their safe deposit box, just prior to making deposits of $3,000 or more in a day, or $5,000 or more in a week, will be asked to substantiate the legitimacy of the funds. If the customer can’t provide sufficient proof, the account will be closed.
  5. Customers that asked to be excluded from CTR reporting will be reported to FinCen via a SAR. Also, their account will be closed.
  6. Customers that refuse to provide the necessary information for filing a CTR will be reported to FinCen via a SAR. Also, their account will be closed.