Why am I being asked to attest to information regarding beneficial ownership?

To help the government fight financial crime, federal regulation requires certain financial institutions to obtain, verify, and record information about the beneficial owners of legal entity customers. Legal entities can be abused to disguise involvement in terrorist financing, money laundering, tax evasion, corruption, fraud, and other financial crimes. Requiring the disclosure of key individuals who ultimately own or control a legal entity (i.e., the beneficial owners) helps law enforcement investigate and prosecute these crimes.

Who must attest to this information?

The Certifying Person – the person opening a new account or otherwise fulfilling the bank’s request to provide this Beneficial Ownership related information – on behalf of a legal entity with any of the following U.S. financial institutions:

1. a bank or credit union;
2. a broker or dealer in securities;
3. a mutual fund;
4. a futures commission merchant; or
5. an introducing broker in commodities.

A legal entity includes a corporation, limited liability company, or other entity that is created by a filing of a public document with a Secretary of State or similar office, a general partnership, and any similar business entity formed in the United States or a foreign country. Legal entity does not include sole proprietorships, unincorporated associations, or natural persons opening accounts on their own behalf.

What information do I have to provide?

The Beneficial Ownership Regulation requires that as of May 11, 2018 that all-natural persons with beneficial ownership or controlling interest in an entity provide their name, address, date of birth and Social Security number (or passport number or other similar information, in the case of non-U.S. persons) for the following individuals:

1. Beneficial Ownership Prong
   1. Each individual who owns, directly or indirectly, any percentage of a company that wishes to open an account at Euro Pacific Bank will be identified.
2. Controlling Interest Prong
   1. An individual with significant responsibility for managing the legal entity customer (e.g., a Chief Executive Officer, Chief Financial Officer, Chief Operating Officer, Managing Member, General Partner, President, Vice President, or Treasurer) The number of individuals that satisfy this definition of “beneficial owner” may vary, depending on the factual circumstances, up to ten individuals (but as few as zero) may need to be identified. Regardless of the number of individuals identified, you must provide the identifying information.

If you would like to read more about this regulation you may access it here: https://www.gpo.gov/fdsys/pkg/FR-2016-05-11/pdf/2016-10567.pdf