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Core Examination Procedures for Regulatory Requirements and Related Topics > Private Banking Due Diligence Program (Non-U.S. Persons)
Short Summary
This document outlines the requirements for U.S. financial institutions to implement a due diligence program for private banking accounts established, administered, or maintained for non-U.S. persons. The program must include policies, procedures, and controls to detect and report money laundering and suspicious activity. Private banking accounts are defined as accounts that require a minimum aggregate deposit of funds or other assets of not less than $1,000,000 and are established on behalf of or for the benefit of one or more non-U.S. persons. The due diligence program must ascertain the identity of account owners, determine if they are senior foreign political figures, ascertain the source of funds deposited into the account, and review account activity for consistency with the client’s information. Enhanced scrutiny is required for accounts with senior foreign political figures as nominal or beneficial owners. The document provides examination procedures to assess compliance with these requirements.
Whom does it apply to?
U.S. financial institutions that establish, maintain, administer, or manage private banking accounts in the United States for non-U.S. persons
What does it govern?
Private Banking Due Diligence Program (Non-U.S. Persons)
What are exemptions?
No exemptions are mentioned.
What are the Penalties?
Not specified.
Jurisdiction
U.S. Federal Government