05.14 – Paper Record search and High Value Accounts

A paper record search will not be required where all the following information is electronically searchable:

  • the account holder’s nationality or residence status;
  • the account holder’s residence address or mailing address currently on file;
  • the account holder’s telephone number(s) currently on file;
  • whether there are standing instructions to transfer funds to another account;
  • whether there is a current “in-care-of” address or “hold mail” address for the account holder; and
  • whether there is any power of attorney or signatory authority for the account.

The paper record search, where necessary, should include a review of the current customer master file and, to the extent 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 with respect to the account;
  • the most recent account opening contract or documentation;
  • the most recent documentation obtained by the Financial Institution for AML/KYC procedures or for other regulatory purposes;
  • any power of attorney or signature authority forms currently in effect; and
  • any standing instructions to transfer funds currently in effect.

These should be reviewed for any US indicia as set at Section 5.5.

A Financial Institution can rely on the review of High Value Accounts performed by third party distributors, for example financial advisers, on their behalf where there is a contract obligating the distributor to perform the review.