Title
Customer Identification for Banks
Law
Bsp Memorandum No. M-2014-043
Decision Date
Nov 7, 2014
BSP Memorandum Order No. M-2014-043 outlines the customer identification requirements for banks in the Philippines, aiming to verify the true identity of customers and ensure the legal existence and organizational structure of entities, in order to protect the integrity of the financial system.

Questions (BSP MEMORANDUM NO. M-2014-043)

To protect the safety, soundness, and integrity of the Philippine financial system by ensuring prudent customer identification processes, including verification of true identity and, for certain entities, verification of legal existence and authority.

A system for verifying the true identity of customers; for corporate/juridical entities, verification of legal existence and organizational structure, and the authority/identity of persons purporting to act on their behalf.

The account must be under the true and full name of the account owner(s).

Only if the alias is duly registered with the relevant government agency pursuant to existing laws and regulations.

The account must be under the true and full name of the entity.

Procedures for identifying the corporate/partnership/sole proprietorship entity and the stockholders/partners/owners, directors, officers, and authorized signatory(ies) authorized to act for the entity.

Banks must establish their true and full identity, as well as the identity of trustees, nominees, agents, or intermediaries, consistent with Subsection X806.1.e.1 of the MORB.

Banks must identify not only the person/entity on whose behalf the account is opened but also the relevant intermediary roles (trustees/nominees/agents/intermediaries) and verify their true identities.

They must comply with the rules applicable to individual customers, particularly the requirement to use the true and full identity and allowable alias rules.

Subsection X806.1, as indicated in the Memorandum.

Subsection X806.1.e.1.

Because persons may purport to act on behalf of entities; banks must verify both their identity and their authority to open and operate accounts, supporting integrity and preventing fraud.

No. It states that for individual customers, the account must be under the true and full name, with alias allowed only under specific registration conditions.

Proof that the alias is duly registered with the relevant government agency pursuant to applicable laws and regulations.

Stockholders/partners/owners, directors, officers, and authorized signatory(ies), in addition to verifying the corporation’s true and full name and legal existence/structure.

The entity must comply with the rules applicable to individual customers, meaning the bank should follow individual-customer identity requirements for account opening.


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