To help investigate and prosecute financial crimes (terrorist financing, money laundering, tax evasion, fraud, and so on), federal regulation requires us to obtain, verify, and record information about the beneficial owners of legal entity clients on the Certification Regarding Beneficial Owners of Legal Entity Customers form.
Use Verafin and the chart below to capture beneficial ownership and controlling ownership. Once you have done this, Verafin produces the certification form.
A client due diligence questionnaire using Verafin is required for ALL new or existing clients requesting a new account or revising signature cards on an existing account.
For more on Verafin click here for additional job aides, demonstrations and resources for using Verafin.
| Account Type | Verafin Business Type | Completion of General Information |
Completion of Beneficial Ownership Information |
Completion of Controlling Ownership Information |
Certification Form Required |
|---|---|---|---|---|---|
| Association | Non-Profit | Yes | No | Yes | No |
| Campaign | Government | Yes | No | Yes | No |
| Club or Civic Group | Non-Profit | Yes | No | Yes | No |
| Corporation - For-Profit |
Corporation | Yes | Yes | Yes | Yes |
| Corporation - Non-Profit |
Non-Profit | Yes | No | Yes | Yes |
| IOLTA | Based on Entity Type | Yes | Yes | Yes | Yes |
| Limited Liability - Single Member | Single-Member LLC | Yes | Yes | Yes | Yes |
| Limited Liability | Limited Liability Company | Yes | Yes | Yes | Yes |
| Limited Liability - Partnership | Limited Liability Partnership | Yes | Yes | Yes | Yes |
| Partnership | Partnership | Yes | Yes | Yes | Yes |
| Political Action Committee | Government | Yes | No | Yes | Yes |
| Public and US Government Funds - Based on Entity | Government | Yes | No | No | No |
| Sole Proprietorship (D/B/A) | Sole Proprietorship | Yes | No | No | No |
| Trust - Business | Trust | Yes | Yes | Yes | Yes |
| Trust - Personal | Trust | Yes | No | No | No |
| Estate | Estate | Yes | No | No | No |