Customer identification procedures recommended by some bank supervisory agencies suggest that in certain cases the institution visit the premises of business customers to verify existence and legitimacy. Benex, BECS and Lowland, all of which had offices in BONY s primary service area, were not registered under New York law as money transmitters. A financial institution should insist on receiving from all customers who are required to be licensed a copy of their license and other documentation pertaining to the history of the company including disciplinary actions by any government agency if that can be disclosed. Edwards served as an officer of Benex, as a director of BECS, and as signatory on the BECS account. For accounts, such as those of these companies, that engage in extraordinarily large volumes of wire transfers, which federal agencies say is a high-risk activity, the institution should have exception controls that trigger deeper monitoring of the customer s activities and of its officers and directors.
State records reveal the names of corporate officers and directors.
It is a prudent practice to examine those records, especially for high-risk customers, to see if bank employees appear on the state records. The criminal information says the software enables the customer to effect wire transfers in its account and to access information about its account from its own computer. If a financial institution is to permit the use of its wire transfer software by its customers it must do so under the tightest of conditions. It is unlikely that the institution could escape blame for transactions involving criminal proceeds facilitated through its software just because a customer was punching the keyboard on the computer. Russian banks transferred billions of dollars into the Benex, BECS and Lowland accounts through their correspondent bank accounts at BONY, some of which Edwards had opened.