103420 – Due Diligence: Entity Accounts: New Accounts

The due diligence procedures for New Entity Accounts are broadly the same as those for Pre-existing Entity Accounts except that there is no de minimis threshold.

Reporting Financial Institutions must determine:

  • whether a New Entity Account is held by one or more Entities that are Reportable Persons; and
  • whether a New Entity Account is held by one or more Entities that are Passive NFEs with one or more Controlling Persons who are Reportable Persons.

The following review procedures must be applied to determine this.