Overview
Due to a high level of risk, certain entity types, along with their product and service providers, are prohibited from obtaining accounts at Capital City Bank unless approved by a BSA officer. Associates and officers must be familiar with the prohibited and restricted lists prior to establishing banking relationships with clients. Associates and officers must obtain BSA officer approval prior to opening an account for a prohibited entity, product, service or a restricted client type.
The tabs below outline the prohibited entity types, products, services and the BSA approval process.
Prohibited Entity Types
Unless BSA officer approval is received, the following entities are prohibited from obtaining accounts:
- Any entity prohibited by law in the entity’s locality
- Entities involved in activities that violate federal or state law
- Foreign financial institutions
- Foreign non-bank financial institutions including foreign money services businesses
- Internet gambling businesses
- Offshore banks
- Third-party Payment Processors (TPPPs)
- Marijuana-related businesses (MRBs):
Tier 1 MRBs
Businesses licensed by the state for production or distribution and businesses that have direct contact with production or distribution are prohibited.
Tier 2 MRBs
Indirect suppliers of products or services to Tier 1 MRBs with more than 50% of their revenue coming from Tier 1 companies and related parties are prohibited.
Examples include:
- Contractors (plumbing, electric, HVAC, building maintenance)
- Landlords
- Irrigation suppliers
- Payment processor
- Packaging supplier
- Advertising
- Software suppliers
- Labor services
- Hydroponic supply providers
Exception
Capital City Bank will consider client relationships with Tier 2 businesses if the following conditions are met:
- Initial client relationship began at least 1 year prior to MRB activity beginning
- MRB related revenue represents income from a temporary contract, not to exceed 1.5 years
- If the temporary contract extends beyond 1.5 years, the relationship with CCB will be terminated
Proper financial analysis is required to show evidence of annual income and expected at the beginning and end of the revenue flow in order to invoke waiver status. All appropriate regulatory reporting will continue through the activity periods.
Prohibited Products and Services
Do not open an account for an entity performing or offering the following products and services, unless approved by a BSA officer:
- Client access to internal concentration accounts used for accounting purposes such as suspense and settlement accounts
- Foreign correspondent banking
- International shipments of currency either into or out of the United States
- Non-client purchases of cashier checks
- Non-client wire transfer requests or payable upon proper identification (PUPID)
- Parallel banking relationships
- Payable through accounts
- Pouch activity
- Safe deposit rentals without a deposit account relationship
- U.S. Dollar draft sales
Restricted Client Types
Unless BSA officer approval is received, the following client types are prohibited from obtaining accounts:
- Casinos and card clubs
- Foreign businesses defined as:
- Foreign corporations, foreign partnerships, foreign trusts, or foreign estates created or organized outside of the U.S. or of any state or the District of Columbia
- Foreign business that does not have any ties to the U.S. (no operations in the U.S.)
- Foreign embassies, consulates, and diplomatic missions
- International Business Corporations (IBCs)
- Money Services Businesses (MSBs)
- Private ATM Owners (PATMO)
- Payday lenders
- Third-Party Payment Processors (TPPPS)
- Marijuana-related Businesses (MRBs)
Tier 2 MRBs
Indirect suppliers of products or services with less than 50% of the revenue coming from to Tier 1 MRB companies or related parties are restricted.
Examples include:
- Contractors (plumbing, electric, HVAC, building maintenance),
- Landlords
- Irrigation suppliers
- Payment processor
- Packaging supplier
- Advertising
- Software suppliers
- Labor services
- Hydroponic supply providers
Tier 3 MRBs
Businesses with yearly sales to MRBs in which those sales are incidental to the overall business and revenue. Includes businesses such as professional services firms and commercial property owners.
Note: A request to open an account for a business that is involved in the sale of firearms does NOT require approval; however, a copy of the state issued firearms license is to be obtained and emailed to the BSA Officer prior to opening.
BSA Approval Process
Associates and officers MUST obtain BSA officer approval prior to opening an account for a prohibited entity, product, service or a restricted client type.
To obtain BSA approval, do the following:
- If applicable, complete a Money Services Business (MSB) /Check Casher (CC) Agreement or Privately Owned ATM (PATMO) Account Request form.
- Email the completed agreement or form to _BSA Department.
- Include details about the client and any relationship details.
- If the BSA officer approves the account opening, print the approval email.
- Include the printed email approval from BSA and the completed MSB/CC Agreement or PATMO Account Request form with the new account documents.