Can a credit union rely on existing information to verify a beneficial owner who is already a member?

Credit unions are permitted to rely on existing information to verify a beneficial owner who is already a member, provided that the information is up-to-date and accurate. This approach aligns with the principles of efficiency and practicality in compliance with the Bank Secrecy Act (BSA) and its regulations concerning Customer Due Diligence (CDD).

When a member is already on file and their beneficial ownership information has been previously verified, it is unnecessary to conduct a full re-verification for every subsequent transaction or account maintenance, as long as there are no significant changes in the ownership structure or the nature of the account that would warrant a new assessment. This helps credit unions streamline their processes while still maintaining compliance with regulatory requirements.

In short, the ability to utilize existing member information acknowledges that these members have already undergone scrutiny and have established their identity and ownership claims, thus facilitating ongoing business relationships and reducing redundancies in compliance procedures.