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Foreign individuals maintaining relationships with U.S. banks can be divided into two categories: resident aliens and nonresident aliens (NRA). An NRA is a non-U.S. citizen who is not a lawful, permanent resident of the U.S. during the calendar year, and who does not meet the substantial presence test, or has not been issued an alien registration receipt card (also known as a green card).
Although NRAs are not permanent residents, they often have a legitimate need to open deposit accounts at U.S. financial institutions. The amount of NRA deposits in the U.S. banking system has been estimated to range from hundreds of billions of dollars to about $1 trillion.
How can you open and maintain deposit accounts for nonresident aliens and maintain IRS and BSA compliance? This webinar will examine the impact of FATCA, the required forms, and the acceptable forms of identification for deposit accounts. It will also address related Bank Secrecy Act issues, including CIP and due diligence requirements.
HIGHLIGHTS
Who is a nonresident alien and what are the IRS and BSA requirements for opening deposit accounts?
What are the requirements for W-8 and W-8BEN forms? What is the most recent IRS guidance?
Common questions about the impact of FATCA and acceptable forms of identification
Due diligence requirements for withholding and the “reason to know” principles
What are the BSA issues and CIP due diligence requirements?
TAKE-AWAY TOOLKIT
New account interview question script
Checklist for CIP compliance
Flowchart for appropriate certification of nonresident alien deposit accounts
Links to important IRS instructions and guidance
Employee training log
Quiz you can administer to measure staff learning and a separate answer key
Attendance verification for CE credits provided upon request.
WHO SHOULD ATTEND? Compliance officers, audit staff, risk managers, senior management, deposit operation managers, new account personnel, and customer service representatives.
ABOUT THE PRESENTER – Susan Costonis, Compliance Consulting and Training for FIs, is a compliance consultant and trainer who began her career in 1978. She specializes in compliance management along with deposit and lending regulatory training. Susan has successfully managed compliance programs and exams for institutions that ranged from a community bank to large multi-state bank holding companies. She has been a compliance officer for institutions supervised by the OCC, FDIC, and Federal Reserve. Susan has been a Certified Regulatory Compliance Manager since 1998, completed the ABA Graduate Compliance School, and graduated from the University of Akron and the Graduate Banking School of the University of Colorado. She regularly presents to financial institution audiences in several states and “translates” complex regulations into simple concepts by using humor and real life examples.
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