IEIM402920 - Due Diligence: Pre-Existing Individual Accounts: Higher Value Accounts: Electronic Records Search

For high value accounts a Financial Institution must review its electronically searchable data [link IEIM402300] for indicia of the individual’s residence (or, alternatively, citizenship for US reporting under FATCA).

The Account Holder will be regarded as a resident of a Reportable Jurisdiction [see IEIM402340] if any if the indicia below apply:

  • The Account Holder is identified as resident of a Reportable Jurisdiction or as a US citizen [see IEIM402800].

  • For FATCA only, there is an unambiguous indication of a US place of birth [see IEIM402820].

  • The current mailing or residence address (including a post office box) of the Account Holder is in a Reportable Jurisdiction [see IEIM402840].

  • There are one or more current telephone numbers in a Reportable Jurisdiction [see IEIM402844].

  • Standing instructions to transfer funds to an account maintained in a Reportable Jurisdiction (other than a Depository Account) [see IEIM402847].

  • A current effective power of attorney or signatory authority granted to a person with an address in a Reportable Jurisdiction [see IEIM402855].

  • A “hold mail” instruction, or an “in-care-of” address in a Reportable Jurisdiction, if the reporting financial institution does not have any other address on file for the Account Holder [see IEIM402850].

To the extent that the Financial Institution’s electronically searchable databases do not include fields for the above or do not otherwise capture this information a paper record search will be required [see IEIM402940]. Where the electronically searchable databases include fields for the required information but are left blank a paper record search will be required unless the Financial Institution has policies and procedures in place that mean that a field is only left blank when the information is not in the Financial Institutions records. For example, a blank field in respect of the sixth bullet above would indicate positively that the Financial Institution does not hold a power of attorney or other signatory authority for the Account Holder.