MORNBFI Vol. 1 - Planters Development Bank

APP. Q-23-e08.12.31monetary value, it might be sufficient torequire and record only name and address.16. It is important that the customeracceptance policy is not so restrictive thatit results in a denial of access by thegeneral public to banking services,especially for people who are financiallyor socially disadvantaged.B. Institutions17. The underlying principles ofcustomer identification for natural personshave equal application to customeridentification for all institutions. Where inthe following the identification andverification of natural persons is involved,the foregoing guidance in respect of suchpersons should have equal application.18. The term institution includes anyentity that is not a natural person. Inconsidering the customer identificationguidance for the different types ofinstitutions, particular attention should begiven to the different levels of riskinvolved.I. Corporate Entities19. For corporate entities (i.e.corporations and partnerships), thefollowing information should be obtained:• name of institution;• principal place of institution’sbusiness operations;• mailing address of institution;• contact telephone and fax numbers;• some form of official identificationnumber, if available (e.g. tax identificationnumber);• the original or certified copy of theCertificate of Incorporation andMemorandum and Articles of Association;• the resolution of the Board ofDirectors to open an account andidentification of those who have authorityto operate the account;• nature and purpose of business andits legitimacy.20. The bank should verify thisinformation by at least one of the followingmethods:• for established corporate entities –reviewing a copy of the latest report andaccounts (audited, if available);• conducting an inquiry by a businessinformation service, or an undertaking froma reputable and known firm of lawyers oraccountants confirming the documentssubmitted;• undertaking a company searchand/or other commercial enquiries to seethat the institution has not been, or is notin the process of being, dissolved, struckoff, wound up or terminated;• utilising an independentinformation verification process, such asby accessing public and private databases;• obtaining prior bank references;• visiting the corporate entity, wherepractical;• contacting the corporate entity bytelephone, mail or e-mail.21. The bank should also takereasonable steps to verify the identity andreputation of any agent that opens anaccount on behalf of a corporate customer,if that agent is not an officer of the corporatecustomer.Corporations/Partnerships22. For corporations/partnerships, theprincipal guidance is to look behind theinstitution to identify those who havecontrol over the business and thecompany’s/partnership’s assets, includingthose who have ultimate control. Forcorporations, particular attention should bepaid to shareholders, signatories, or otherswho inject a significant proportion of thecapital or financial support or otherwiseexercise control. Where the owner isanother corporate entity or trust, theobjective is to undertake reasonablemeasures to look behind that company orentity and to verify the identity of theManual of Regulations for Non-Bank Financial InstitutionsQ RegulationsAppendix Q-23-e - Page 3