102940 – Due Diligence: Pre-Existing Individual Accounts: High Value Accounts: Paper Record Search

A financial institution must carry out a paper record search to the extent that the information on residence of an Account Holder is not captured by the electronic search. 

For example, where the electronically searchable databases contain all the required information except for details of standing instructions to transfer funds, the paper record search will only be required to look for that information.

The paper record search should include a review of the current master file and, to the extent that they are not contained in the current master file, the following documents associated with the account and obtained by the financial institution within the last five years.

  • The most recent Documentary Evidence collected on the account;
  • The most recent account opening contract or documentation;
  • The most up-to-date documentation obtained by the financial institution for AML/KYC procedures or other regulatory purposes;
  • Any power of attorney or signatory authority currently in effect; and
  • Any standing instructions to transfer funds currently in effect (other than for a Depository Account in the case of the DAC/CRS). 

These should be reviewed for any of the indicia of residence detailed in AEIM 102920.

A financial institution can rely on the review of High Value Accounts by third party service providers where there is a contract obliging the service provider to perform the review.