Identification

Complete the following information: 

1. Enter the name and Social Security Number (SSN).
   • This information is not populated from Jack Henry so use additional care to ensure the information is entered correctly. These are required fields. 
   • Note: If the client does not have a SSN, STOP. We CANNOT open accounts for individuals that do not have a SSN or ITIN.
   • Exceptions to this requirement must be approved by the BSA Officer.
2. If the client does not have a Social Security Number, select No SSN.
   • Verafin displays an alert message. Stop and read the information in the alert before proceeding.
3. If applicable, enter the Doing Business As (DBA) name in the field provided.
4. Enter the Employee Identification Number(EIN), if applicable
   • If the client does not have an EIN, select the No EIN check box. 
5. If Verafin finds a match, a message appears stating that the customer has been identified and the CDD questionnaire populates.
   
6. Complete a new questionnaire or update the existing questionnaire.
   • Note: The questionnaire is to be completed for the client's full relationship with CCB not just the account in question. 

Note: If an error is made in the SSN or EIN, email _BSA Department to notify them of your error and start a new questionnaire.
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Interpreter

Question 1: Is there an interpreter or someone else speaking on behalf of the customer?

• Select Yes or No from the drop down menu.
  • If Yes, collect as much information as possible. 
    • If the interpreter is willing to provide their name but not their SSN, select Yes. Enter the interpreter's name and select the No SSN check box.
    • If the interpreter is not willing to provide their name or SSN, select Yes from the drop down menu. Select the No SSN check box.
    • If you feel the actions are suspicious then report it to the Bank Secrecy Act (BSA) Department on the Unusual Activity Referral (UAR).
  • If No, go to the General Information section.

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General Information

Question 1: Will the account(s) also be used for your personal (for example: non-business) banking activity?

• Select Yes or No.
  • If No, continue to Question 2.
  • If Yes, the client must open a personal account! Using a sole proprietor business account for personal funds is not allowed.

Question 2: What type of business is this?

• Enter the type of business. 
• Be as specific as possible. 
  • This entry drives the options presented in the next field.

Question 3: Select the appropriate North American Industry Classification System (NAICS) code for the business type.

• Use the scroll bar to view additional codes.
• When specific NAICS codes for high risk businesses are selected the required Declared Behavior questions will appear, and are required.

Question 4: Which of the following will your account be used for?

• Select all that apply from the provided checklist.

Question 5: Are you a frequent traveler?

• Select Yes or No.
• If Yes, proceed to Question 6.
• If No, proceed to Question 7.

Note: Advise clients that when they travel they need to contact us to prevent their debit card transactions from being declined due to suspicious activity.

 

Question 6: Do you travel outside of the U.S.?

• Select Yes or No.
• If Yes, select the country or countries of travel.
• If No, proceed to Question 7.

Question 7: Will you be using a safe deposit box? 

• Select Yes or No.

Question 8: Is the business located within the Capital City Bank service area?

• Select Yes or No.
  • If No, document the geographic locations served and the purpose of account with Capital City Bank.

Question 9: Who are your major customers or vendors?

• Document your major customers and estimated total sales as well as your major suppliers and estimated expense.
• Proceed to the Declared Behavior questions, or the next section Nonresident Aliens and Foreign Individuals.

Declared Behavior Questions: Which of the following types of transactions will you perform?

• Select Yes or No to each of the following items:
  • Cash Deposits
  • Cash Withdrawals
  • Will you be using a courier or armored car service to complete your cash transactions?
  • Incoming Wire Transfers
  • Outgoing Wire Transfers
  • Check Deposits
    • Will you be depositing checks remotely using mobile/remote deposit capture?
  • Check Withdrawals
  • Incoming (Non-Wire) Electronic Transfers
  • Outgoing (Non-Wire) Electronic Transfers
  • Money Instrument Purchases
  • ATM Deposits
  • ATM Withdrawals
• If Yes is answered to any of the Declared Behavior questions, follow up questions may appear asking the total amounts expected and whether the transfers will be sent to non-U.S. You may select multiple countries if needed. Ask and answer any follow up questions that were presented.

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Nonresident Aliens and Foreign Individuals

Question 1: Are you a U.S. citizen?

• Select Yes or No.
  • If Yes, ask Question 6.
  • If No, ask Question 2.

Question 2: What is your country of origin (home country or country of citizenship)?

• Select country from the drop down menu.

Question 3: Do you have a Green Card, or are you a foreign resident of the U.S. (legal permanent resident)?

• Select Yes or No.
• If No, ask Question 4.
• If Yes, ask Question 5.

Question 4: Do you have a U.S. Individual Taxpayer Identification Number (TIN)?

• Select Yes or No.

Question 5: What is your Green Card number?

• Enter the Green Card Number

Question 6: Do you have citizenship with any other country?

• Select Yes or No.
• If Yes, ask Question 7.
• If No, proceed to Politically Exposed Persons.

Question 7: With what other countries do you have citizenship?

• Select the country or countries from the drop down menu.
• Important Note: This information is necessary to assist in identifying account activity risk.

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Politically Exposed Persons (PEP)

If Yes is the answer to any of the questions in the section, STOP, and email the BSA Department.

Question 1: Are you, or have you ever been, a politically exposed persons or a senior political figure?

• Select Yes or No.
• Note: PEP includes a senior official of a foreign government or major foreign political party, or executive of a government-owned corporation.

Question 2: Are you an immediate family member or a close associate of someone who is currently, or who was, a PEP?

• Select Family Member, Close Associate, or No.
  • If No, skip to the section Embassy, Foreign Consulate, or Foreign Missions Employee.
  • If Family Member is selected, ask Question 3.
  • If Close Associate is selected, ask Question 4.

Question 3: What is the nature of your relation to him or her?

• Select the relationship from the drop-down menu.

Question 4: What is the nature of your association with him or her?

• Select the association from the drop-down menu.

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Embassy, Foreign Consulate, or Foreign Missions Employee

Question 1: Is the organization an embassy, foreign consulate, or foreign mission?

• Select Yes or No.
  • If No, proceed to the Internet Gambling section.
  • If Yes, STOP and follow the instructions in the Important Message that appears.
    • "Sorry, we cannot proceed any further."

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Internet Gambling

Question 1: Does any portion of business income come from internet gambling?

• Select Yes or No.
  • If No, go to the Marijuana-Related Business section.
  • If Yes, STOP and follow the instructions in the Important Message that appears.
    • "Sorry, we cannot proceed any further."

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Marijuana-Related Business

Question 1: Is this a marijuana related business?

• Select Yes or No.
  • If Yes, STOP and follow the instructions in the Important Message that appears.
  • If No, go to the Hemp-Related Business section.

Question 2: Is any signer affiliated with marijuana-related business?

• Select Yes or No.

Question 3: Are any funds deposited in the account derived from a marijuana-related business?

• Select Yes or No.

E-mail _BSADepartment with any questions.

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Hemp-Related Business

Question 1: Is this a hemp-related business?

• Select Yes or No.
  • If Yes is answered, STOP and follow the instructions in the Important Message that appears.
    • "Sorry, we cannot proceed any further."
• If No, go to the CBD-Related Business question.

CBD-Related Business

Question 1: Is this a CBD-related business?

• Select Yes or No.
  • If Yes is answered, STOP and follow the instructions in the Important Message that appears.
    • "Sorry, we cannot proceed any further."
  • If No, go to the Professional Service Provider question.

Professional Service Providers

Question 1: Do you act as an intermediary between your clients and the bank, performing services or arranging for services to be performed on your client's behalf?

• Select Yes or No.
• If No, go to the Nonbank Financial Institutions (Excluding MSB) section.
• If Yes, STOP and follow the instructions in the Important Message that appears.
  • Complete the questionnaire. 
  • In the Notes section collect the following information:
    • The purpose of the account
    • Products/Services offered
    • Geographic location of clients serviced.
• Note: Email _BSADepartment with questions.

Question 2: What services do you provide?

• Select the service or services provided. 

Question 3: Will other professionals be using this account?

• Select Yes or No.

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Nonbank Financial Institutions (Excluding MSB)

Question 1: Does your business involve any of the following?

• Select all that apply or None of the Above.
• If None of the Above is selected, go to the section Money Service Business (MSB).
• If anything other than None of the Above is selected, STOP and follow the instructions in the Important Message that appears.
  • Complete the questionnaire. 
  • In the Notes section collect the following information:
    • Types of products and services offered
    • Locations and markets serviced
  • If applicable, forward the following documentation to BSA:
    • FinCEN registration
    • State licenses
    • Anti-Money Laundering (AML) Compliance Program 
  • Contact the BSA Department by email with questions.

Note: Some responses prompt Question 2 to appear.

Question 2: Do you have a documented BSA/AML program?

• Select Yes or No.
   

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Money Service Business (MSB)

Question 1: Does your business involve any of the following?

• Select all that apply or None of the Above.
• If None of the Above is selected, go to the section Nongovernmental Organizations or Charities.
• If anything other than None of the Above is selected, STOP and follow the instructions in the Important Message.
  • STOP. Contact the BSA Department. Collect copies of the following documents:
    • FinCEN Registration
    • Agent Agreements
    • AML Compliance Program
    • Most recent audit
  • Contact the BSA Department by email with questions.

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Nongovernmental Organizations or Charities

Question 1: Do you depend, in whole or in part, on charitable donations and voluntary service for support?

• Select Yes or No.
• If No is selected, go to the section Bulk Shipments of Currency.
• If Yes is selected, STOP and follow the instructions in the Important Message.
  • Complete the questionnaire. 
  • In the Notes section collect the following information:
    • Purpose and objectives of activities
    • Geographic locations served
    • Headquarters location
    • Organizational chart
    • Donor/volunteer base
    • Funding/disbursement criteria
    • Recordkeeping requirements
    • Affiliations to other groups 
    • Internal audit control process
  • Contact the BSA Department by email with questions.

Question 2: In what country is your organization chartered?

• Select the country from the list.

Question 3: Do you have donors or volunteers from non-U.S. countries?

• Select Yes or No.
• If No, proceed to the section Bulk Shipments of Currency.
• If Yes, ask Question 4.

Question 4: In what countries are your donors or volunteers located?

• Select the country or countries.

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Bulk Shipments of Currency

Question1: Does your company offer courier or armored car services to ship currency on your customer's behalf?

• Select Yes or No.
• If No, go to the section Third-Party Payment Processors.
• If Yes is selected, STOP and follow the instructions in the Important Message.
  • "Sorry, we cannot proceed any further."
    
     

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Third-Party Payment Processors

Question 1: Will you be processing transactions that benefit a third-party?

• Select Yes or No.
• If No is selected, go to the Notes section.
• If Yes is selected, STOP and follow the instructions in the Important Message.
  • "Sorry, we cannot proceed any further."
    
     

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Privately-owned ATM

Question 1: Do you own, operate, or replenish an Automated Teller Machine (ATM)?

• Select Yes or No.
• If No is selected, go to the Notes section.
• If Yes is selected, STOP and follow the instructions in the Important Message.
  • "STOP, contact the BSA Department."
    
     

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