05.16 – Relationship Manager

In addition to the electronic and paper searches, the Financial Institution must also consider whether any Relationship Manager associated with the account (including any accounts aggregated with such account) has knowledge that would identify the account holder as a Specified US Person. 

If the Relationship Manager knows that the account holder is a Specified US Person, then the account must be reported unless the indicia can be cured.

For these purposes, a Relationship Manager is assumed to be any person who is an officer or other employee of the Financial Institution assigned responsibility for specific account holders on an ongoing basis, and who advises the account holders regarding their accounts and arranges for the overall provision of financial products, services and other related assistance.

A Financial Institution must also ensure that it has procedures in place to capture any change of circumstance in relation to a High Value Individual Account made known to the Relationship Manager in respect of the account holder’s status.

Example 1

If a Relationship Manager is notified that the account holder has a new mailing address in the US, this would be a change in circumstance and the Financial Institution would either need to report the account or obtain the appropriate documentation to cure or repair that indicia.

The electronic search and paper search only need to be done once for each account identified as a High Value Account, but the responsibilities of Relationship Managers to ensure that any knowledge regarding the account holder’s status or aggregation of accounts is captured are constant and ongoing (see 4.14).

If the Relationship Manager has knowledge that there archived records for the account that are not currently treated as maintained for regulatory or customer relationship purposes (see 4.21), such as knowledge that there are archived records that hold alternate addresses, then this in itself is not knowledge that would identify the account holder as a Specified US Person. In order for knowledge of these records to be knowledge that would identify the account holder as a Specified US Person, the Relationship Manager would have actually to know that one or more of those addresses was based in the US.