We are not aware of any law, regulation or guidance that requires you to obtain specific information about the source of a corporate customer’s funds at an account opening. However, if as part of your BSA/AML customer due diligence procedures you determine that this customer presents a higher risk of money laundering or terrorist financing (based on factors such as the customer’s business activity, ownership structure, and volume, type, and location of transactions), then you should engage the customer in enhanced due diligence.

For customers that require enhanced due diligence, the FFIEC recommends — but does not require — that you obtain certain customer information both at account opening and throughout the relationship, including the source of the customer’s funds.

For resources related to our guidance, please see:

• FFIEC BSA/AML Examination Manual, Customer Due Diligence — Overview (“Customers that pose higher money laundering or terrorist financing risks present increased exposure to banks; due diligence policies, procedures, and processes should be enhanced as a result. The bank may determine that a customer poses a higher risk because of the customer’s business activity, ownership structure, anticipated or actual volume and types of transactions, including those transactions involving higher-risk jurisdictions. If so, the bank should consider obtaining, both at account opening and throughout the relationship, the following information on the customer: . . . Source of funds and wealth . . .”)

• FinCEN Guidance, FIN-2010-G001 (March 05, 2010) (“With respect to accounts that have been identified by an institution's CDD procedures as posing a heightened risk, these accounts should be subjected to enhanced due diligence (EDD) that is reasonably designed to enable compliance with the requirements of the BSA. This may include steps, in accordance with the level of risk presented . . . to reasonably understand the sources and uses of funds in the account . . .”)