From The Shield: A security newsletter for businesses • Spring 2016
Since the events of September 11, 2001, banks and regulators are more focused on limiting the potential for financing terrorist and drug-related activities through our financial system. As a result, banks have increased their efforts to prevent money laundering and terrorist financing, and to comply with anti-money laundering (AML) regulations. These efforts are, in turn, a driving factor in determining which information is currently required from customers in order to process their transactions.
In August 2014, the U.S. government issued an Advanced Notice of Proposed Rulemaking entitled “Customer Due Diligence Requirements for Financial Institutions.” When final, the rule will require banks to verify the identities of “beneficial owners” of most legal entity customers, including corporations, LLCs, partnerships, unincorporated non-profits and statutory trusts. “Beneficial owner” is defined as “the natural person(s) who ultimately owns or controls a customer and/or the person on whose behalf a transaction is being conducted.” Beneficial owner also pertains to an individual with an ultimate ownership stake of 25% or more of the equity interest, and an individual who exercises significant authority to control the legal entity customer’s affairs.
As a result of the enhanced due diligence requirements, U.S. Bank may request the following information and documentation from beneficial owners and authorized signers of new and existing legal entity customers:
- Full legal name
- Date of birth
- Current residential address
- Social Security number or other government-issued ID number for non-U.S. citizens
U.S. Bank, in some instances, may also request documentary evidence (e.g., driver’s license) to verify the information provided.
Information collected from beneficial owners or authorized signers is not shared outside of U.S. Bank, its subsidiaries or affiliates. Sharing this data within the bank only occurs for purposes of complying with anti-money laundering laws and regulations. Access to collected information is limited to users on a need-to-know basis.
U.S. Bank ranked first in the Ponemon Institute 2015 “Privacy Trust Study for Retail Banking” and has ranked first for the past nine years. We have a legal and ethical responsibility to ensure information is secure and accurately maintained. U.S. Bank is committed to protecting the confidentiality, integrity, availability and privacy of our customers’ data. Our reputation rests, in part, upon securely maintaining our customers’ information assets.
Other News In the 2016 Spring issue:
- Combatting destructive malware
- Five tips to help safeguard your organization
- Cybersecurity from an executive perspective
- How U.S. Bank Collects & Safeguards Your Information
Find out more about practice financing options from Jennifer Maschke, NDA member.