Section 312: Correspondent and Private Banking Accounts

Question 1

Per Sec 312,when should tbe edd be conducted on private bank correspondent accounts

Answer 1

private banking accounts maintained for senior

foreign political figures, their immediate family and their close associates.

Question 2

Per Sec 312 , what defines a private banking account

Answer 2

an account with a minimum aggregate
deposit of $1 million, (b) for one or more non-US persons, and (c) which is assigned to a bank
employee acting as a liaison with the non-US person.

Question 3

per 312 , what reasonable steps should US institutions take for Private bank accounts

Answer 3

Ascertain the identity of all nominal and beneficial owners of the accounts.
• Ascertain whether any such owner is a “senior foreign political figure.”
• Ascertain the source of the funds in the account and the purpose and expected use of the
account.
• Monitor the account to ensure the activity in the account is consistent with the information
provided as to the source of funds and the purpose and expected use of the account, as needed
to guard against money laundering and to report any suspected money laundering or suspicious
activity.

Question 4

When ascertained whether the account is of a “senior foreign political figure, what should the FI do

Answer 4

1. current or former
2. immediate family members and persons
3. widely and publicly known” to be close associates.