We have an existing customer that is a convenience store and now selling CBD Oil. We have requested a copy of his permit, a list of his suppliers and a copy of his permit application with all documents he provided for the permit. Is the copy of the app required or do we need anything else other than what we requested? Thanks for any input!
How would you address someone in your policies and procedures who has bought stocks in a MRB. Their ownership would be minimal ( 1 of say 200 shareholders) would you consider the relationship that person is involved with to be high risk? In our hypothetical situation - this beneficial owner may own many businesses, but on their account due diligence they have indicated they have purchased shares in a MRB. Would this person be rated as a tier 3 person and have a high risk assigned. What about filing the initial SAR? Thank you everyone. I am just trying to brainstorm possible scenarios in my risk assessment, policy definitions and procedures.