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An executor walks in with a folder of papers, a death certificate and a question: "How do I open an account for my mother's estate?" Handled well, this becomes a clean fiduciary relationship. The bank knows who has authority, the account carries the right taxpayer number, and every dollar in and out can be traced when the estate closes. Handled badly, it becomes an account opened under the decedent's Social Security number, a signer whose authority was never checked, and post-death federal ...

Most CDD failures happen at the desk, not in the BSA department. A beneficial ownership form missing the control person, an expected-activity field that says "normal," a nonprofit opened without anyone asking where its money goes: each of these gets discovered months later by an analyst trying to clear an alert against a profile that was never built.

This template is for account-opening staff and the people who review their work. It is organized by customer type, because what you ...

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