No, you are not required to obtain identifying information on authorized signers (other than for the account owner). But it may be prudent to also obtain identifying information on certain authorized signers, depending on your bank’s assessment of their risk. Both interagency and FinCEN guidance suggest obtaining identifying information on some or all account signatories for higher risk accounts.

For resources related to our guidance, please see:

• Interagency FAQs, Customer Identification Program Rule (April 28, 2005), printed page 7 (“10. Who is the ‘customer’ for purposes of escrow accounts? . . . . the CIP rule also provides that, based on the bank’s risk assessment of a new account opened by a customer that is not an individual, the bank may need ‘to obtain information about’ individuals with authority or control over such an account, including signatories, in order to verify the customer’s identity. See 31 C.F.R. § 103.121(b)(2)(ii)(C).”)

• FFIEC BSA/AML Examination Manual, Customer Due Diligence (If a bank determines that a customer presents a higher risk, then “the bank should consider obtaining” information on “individuals with ownership or control over the account, such as beneficial owners, signatories, or guarantors.”)

• FFIEC BSA/AML Examination Manual, Business Entities (“Required account opening information may include . . . the appointment of a person to act as a signatory for the entity on the account.”)