CIP FAQs – Does a bank have to provide notice to all owners of a joint account?

Compliance > BSA > FinCEN FAQs - CIP
Q:  Does a bank have to provide notice to all owners of a joint account?
 
A:  Yes, notice must be provided to all owners of a joint account.  In addition, notice must be provided “in a manner reasonably designed to ensure that a customer is able to view the notice, or is otherwise given notice, before opening an account.”  31 C.F.R. § 103.121(b)(5)(ii).  The Agencies agree that a bank may satisfy this requirement by directly providing the notice to any one accountholder of a joint account for delivery to the other owners of the account.  Similarly, the bank may open a joint account using information about each of the accountholders obtained from one accountholder, acting on behalf of the other joint accountholders.  (January 2004)
 

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
 

Add Feedback