IMPORTANT INFORMATION FOR NEW & EXISTING BUSINESS CLIENTS REGARDING NEW FEDERAL BENEFICIAL OWNERSHIP RULE

In order to facilitate law enforcement efforts to combat various illegal activities, including drug trafficking, organized crime and terrorism, certain laws have been passed and government initiatives established to inhibit or identify money laundering. Laws and directives requiring action by banks, credit unions and other financial institutions include the Bank Secrecy Act, The USA Patriot Act and directives issued by agencies of the U.S. Department of Treasury (specifically, the Financial Crimes Enforcement Network (FinCEN) and the Office of Foreign Assets Control (OFAC)). The Rule requires the disclosure of key individuals who own or control a legal entity (Beneficial Owners).

Beneficial Owners are defined in the Rule as individuals who meet the following “Ownership” or “Control” criteria:

Ownership: Each individual who owns, directly or indirectly, 25% or more of the equity interests of the legal entity.

 

Control: An individual with significant responsibility for managing the legal entity, such as an executive officer or senior manager (e.g. CEO, CFO, COO, managing member, General Partner, President, Vice-President or Treasurer) or any other individual who regularly performs similar functions. While many legal entities will have more than one individual with significant management responsibility, only one of those individuals is required to be disclosed under the Rule.

An authorized representative of the legal entity will be required to provide and certify the accuracy of the following information for each identified beneficial owner:

• Full legal name;
• Date of Birth;
• Residential or Business Street Address (cannot be a PO Box);
• Social Security Number or Passport Number and Country;
• Ownership Percentage (not required for control person); and
• Copy of driver's license, passport or other valid government-issued photo identification.