CIP FAQs - Are data processing, data warehousing, and data transmission on behalf of a person an “account?”

Compliance > BSA > FinCEN FAQs - CIP
Q:  Are data processing, data warehousing, and data transmission on behalf of a person an “account?”
 
A:  “Account” is defined to mean “a formal banking relationship established to provide or engage in services, dealings, or other financial transactions including a deposit account, a transaction or asset account, a credit account, or other extension of credit.  Account also includes a relationship established to provide a safety deposit box or other safekeeping services, or cash management, custodian and trust services.”   The examples provided in 31 C.F.R. § 103.121(a)(1) of formal banking relationships included within the meaning of “account” focus on bank products and services that relate to the deposit, lending or custody of funds or other assets on behalf of a customer.  Data processing, warehousing, and transmission services generally do not involve a service, dealing, or financial transaction that, taken alone, constitutes a “formal banking relationship” within the meaning of 31 C.F.R. § 103.121(a)(1).  If, however, any of these services are part of the establishment of a formal banking relationship, then the CIP rule in 31 C.F.R. § 103.121 would apply.  (April 2005)
 

ADDITIONAL INFORMATION
This FAQ was excerpted from the Interagency Interpretive Guidance on CIP Requirements that can be found at the following link:  https://www.fincen.gov/sites/default/files/guidance/faqsfinalciprule.pdf
 

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