(ii) to anyone who does not have a residence or business address, who does not have a boxing number of the Military Post Office (APO) or Fleet Post Office (OPS) or who has the residence or business address of his or her close relatives or other contact; in the case of a fiduciary account, the client is the agent, whether the bank is a fiduciary or not. A bank is not required to search trust accounts, trust accounts or similar accounts to verify the identity of the beneficiaries, but only to verify the identity of the designated account holder. See 68 FR 25090, 25094 (May 9, 2003). However, the CIP rule also provides that, on the basis of the risk assessment of a new account opened by a non-individual customer, the bank must obtain information about persons with authority or control of such an account, including the signatories, in order to verify the identity of the customer. See 31 C.F.R. 103.121 (b) (2) (ii) (C). For example, in certain circumstances involving retractable trusts, the bank may be required to collect information about the administrator, the funder, the agent or other persons empowered to lead the trustee, thus having the authority or control of the account to establish the client`s true identity. (April 2005) The bank must verify the identity of its customer within a reasonable time after the account has been opened. The identification check should at least verify the credentials mentioned above. There are two methods of verifying identification: document verification and non-documentary verification. Although banks are not required to use documentary methods to verify a client`s identity, they must document the non-documentary verification procedure in the same way as during the document audit conducted as part of their IPC.

Are not documentary: No, FCM or IB can only do so if the client has requested a tax identification number, the FCM or IB confirms that the application was filed before the client opened the account, and the FCM or IB receives the tax identification number within a reasonable time after the account is opened. Note, however, that when opening a new account for a client with an existing account, a FCM or IB should not receive a tax identification number, provided that FCM or IB is satisfied that it knows the client`s true identity.