MORNBFI Vol. 1 - Planters Development Bank

APP. Q-23-e08.12.31principals. What constitutes control for thispurpose will depend on the nature of acompany, and may rest in those who aremandated to manage funds, accounts orinvestments without requiring furtherauthorization, and who would be in aposition to override internal proceduresand control mechanisms. For partnerships,each partner should be identified and it isalso important to identify immediate familymembers that have ownership control.23. Where a company is listed on arecognized stock exchange or is asubsidiary of such a company then thecompany itself may be considered to bethe principal to be identified. However,consideration should be given to whetherthere is effective control of a listedcompany by an individual, small groupof individuals or another corporate entityor trust. If this is the case then thosecontrollers should also be considered tobe principals and identified accordingly.II. Other Types of Institution24. For the account categories referredto paragraphs 26 to 34, the followinginformation should be obtained in additionto that required to verify the identity of theprincipals:• name of account;• mailing address;• contact telephone and faxnumbers;• some form of official identificationnumber, if available (e.g. tax identificationnumber);• description of the purpose/activitiesof the account holder (e.g. in a formalconstitution);• copy of documentation confirmingthe legal existence of the account holder(e.g. register of charities).25. The bank should verify thisinformation by at least one of the following:• obtaining an independentundertaking from a reputable and knownfirm of lawyers or accountants confirmingthe documents submitted;• obtaining prior bank references;• accessing public and privatedatabases or official sources.Retirement Benefit Programmes26. Where an occupational pensionprogramme, employee benefit trust orshare option plan is an applicant for anaccount the trustee and any other personwho has control over the relationship(e.g. administrator, programme manager,and account signatories) should beconsidered as principals and the bankshould take steps to verify their identities.Mutuals/Friendly Societies, Cooperativesand Provident Societies27. Where these entities are anapplicant for an account, the principals tobe identified should be considered to bethose persons exercising control orsignificant influence over the organization’sassets. This will often include boardmembers plus executives and accountsignatories.Charities, Clubs and Associations28. In the case of accounts to beopened for charities, clubs, and societies,the bank should take reasonable steps toidentify and verify at least two signatoriesalong with the institution itself. Theprincipals who should be identified shouldbe considered to be those personsexercising control or significant influenceover the organization’s assets. This will ofteninclude members of a governing body orcommittee, the President, any boardmembers, the treasurer, and all signatories.29. In all cases independent verificationshould be obtained that the personsinvolved are true representatives of theinstitution. Independent confirmationshould also be obtained of the purpose ofthe institution.Q RegulationsAppendix Q-23-e - Page 4Manual of Regulations for Non-Bank Financial Institutions