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These regulations require banks to report transactions that have no apparent lawful purpose or are not the sort in which the particular customer would be expected to engage.

The first and most essential step in effective customer due diligence is verifying the identity of the customer. Present guidelines for the opening of personal accounts include: obtain satisfactory customer identification; consider the proximity of the customer’s residence or place of business; call-verify the customer’s residence or place of employment; consider the source of funds used to open the account; and check prior banking references for larger accounts. Additional steps may include third-party references, verification services, and the use of Internet search techniques. In addition to verifying the legal status of businesses opening accounts, bankers should determine the source of funds and the beneficial owners of all accounts. The existence of most businesses can be verified through an information-reporting agency, banking references, or by visiting the customer’s business.

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