AML Guidance for IBs Regarding Unusual Situations

CFTC, FinCEN and Treasury have provided guidance in a Q&A format regarding certain unique circumstances relating to IBs and the Customer Identification Program (CIP).  These include: New Co-Owner of Account: If a person becomes a co-owner of an existing account, then the new co-owner is a customer to which the IB must perform the CIP…....

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