CIP and Beneficial Owners for Deposit Accounts

Recorded: August 5, 2025
Presented by: Natalie Straus, Director, Forvis Mazars, LLP

The establishment of deposit accounts requires consideration of some seriously important federal regulations. Some of our most important responsibilities come from two components of the Bank Secrecy Act: Customer Identification Procedures and Beneficial Ownership Requirements. Our institutions are expected to have procedures in place to satisfy these requirements when we open deposit accounts. That means that we need to have a solid understanding of our responsibilities under this regulation and how they will apply to specific account types.

HERE IS WHAT YOU WILL LEARN:

• CIP program components and requirements
• Whose identity do you verify for personal accounts? Business accounts? Fiduciary accounts?
• What documents do we have to collect at account opening?
• Procedures to identify and verify beneficial owners
• When do we need beneficial owner information?
• What is the control prong? What is the ownership prong?
• How do we verify the information?

HERE ARE THE SPECIFIC ACCOUNT TYPES AND TOPICS WE WILL COVER:

• Single Party Accounts
• Multiple Party Accounts
• Fiduciary Accounts
• Legal Entity Accounts