TOPIC: Beneficial Ownership

Government Entity Accounts

Manager at a credit_union ($732MUSA)
We are considering opening accounts for government entities. Currently, we only open accounts for natural persons, non-profit organizations and sole proprietorship DBAs. Does anyone open accounts for government entities and would you be willing to share your procedures? Also, what compliance requirements and risk considerations should we be aware of? Thank you! 

    Trust in Jersey, one of the Channel Islands and Beneficial ownship

    COO at a bank ($373MUSA)
    There are two borrowing entities, owned by the same trust and looks like both are set up the same way. 
    • Borrower = Fun Hotel Co LLC, a Delaware LLC, 
    • Crazy Hotel Inc. a Delaware corp, is the sole member of Fun Hotel LLC. Bill Smith is named as President of Crazy Hotel, Inc. ( I believe Bill is the son of Joe and Jane Smith in #3)
    • The Good Times 2019 Trust, with The Good Times Private Trust Company, Trustee, owns 100% of Crazy Hotel.  The Good Times 2019 Trust, was established in 2019 under the trust laws of Jersey, in the Channel Islands.  John Doe, Joe Smith and Jane Smith (husband and wife) are named as directors of the trust.  When reading up on Jersey law, a director of a trust basically carries the same responsibilities as a corporation director, which is to act un the best interest of the trust.  In essence then, there is no physical person listed as a trustee, or successor trustee.

    Here are a couple of other odd things.

    1. The business address for Fun Hotel LLC is the address of Crazy Hotel inc., but the mailing address for Fun Hotel LLC is in Dubai.  2. The actual person opening the account is Bill Smith, who uses a United Kingdom DL

    We have completed the beneficial ownership certification as The Good Times Private Trust Company, Trustee, as 100% owner of Fun Hotel Co, LLC.  Does that sound right?  

    Also does anyone know how can we confirm the legitimacy of the Jersey Trust agreement?




      Paycheck Protection Program | BSA Requirements Still Apply

      I know there have been a lot of questions surrounding BSA requirements with the Paycheck Protection Program loans through the CARES Act. This blog goes over what is required of financial institutions issuing these loans as the BSA requirements have not been loosened and you are still required to obtain beneficial ownership information. When considering entering the PPP as an approved lender, you should feel confident in your existing onboarding processes to cover any BSA requirements. If a strong BSA program is in place and includes robust transaction monitoring, your institution should onboard these new loans with little additional BSA risk.

      Read the full blog here.

        The Beneficial Owner is deceased

        Employee at a bank ($973MUSA)
        We have a corporation who is changing signers but the beneficial owner is a trust who's beneficial owner is deceased.  Do you still list the deceased person as the beneficial ownership and the trust manager as the control or do we just say no beneficial owner and list the control ? How would you proceed or does anyone have any guidance they can point me towards?