IBA Compliance Connection

Your go to source for compliance!

We received an “AML ETF Questionnaire” from Visa. The questionnaire requires us to list all board members and key executives. It also requires a name and percentage of ownership for each of our stockholders, which we view as private information (we are not publicly traded). Visa is threatening to impose large fines (over $10,000) if we fail to complete the survey. Are other institutions submitting this information?

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Yes, other Illinois institutions have reported receiving similar surveys, although the surveys do not always require that level of detail about staff and ownership that Visa is requiring from your bank. We do recommend completing the survey, assuming that it is required by your contract with Visa.

One IBA member shared a possible solution with us regarding shareholder information. The bank listed the name of its holding company as its sole shareholder, with 100% ownership. Because your bank also operates under a holding company, that solution may work for you.