31 C.F.R. §1010.605(m): “Private Banking Account”

31 CFR § 1010.605 – Definitions. (m) Private banking account means an account (or any combination of accounts) maintained at a covered financial institution that: (1) Requires a minimum aggregate deposit of funds or other assets of not less than $1,000,000; (2) Is established on behalf of or for the benefit of one or more non-U.S. persons who are direct or beneficial…

Read More

Financial Institutions: The Challenge. Compelled “U.S. person” status

1. Background Although the Internal Revenue Code properly recognizes your right to choose a nonresident alien status and be unenumerated, banks and financial institutions are so heavily regulated that they often take a position at odds with this lifestyle. As part of their Anti-Money Laundering (AML) and Bank Secrecy Act (BSA) compliance measures, financial institutions…

Read More