Notice to Customers of Identity Verification Requirements

To help the government fight the funding of terrorism and money laundering activities, federal law requires all US financial institutions to obtain, verify and record information that identifies each person who opens an account.

What this means for you: When you open an account, we will ask for your name, address, date of birth, and other information that will allow us to identify you. We may also ask to see your identifying documents.

USA PATRIOT Act Anti-Money Laundering Requirements for Foreign Correspondent Institutions

Section 313 of the USA PATRIOT Act prohibits US financial institutions from establishing, maintaining, administrating or managing correspondent accounts for foreign shell banks. US financial institutions are required to take reasonable steps to ensure that they are not providing banking services to foreign shell banks indirectly through correspondent accounts maintained for other foreign banks. A shell bank is a foreign bank with no physical presence in any country.

Section 319(b) of the Act requires US financial institutions that provide a correspondent account to a foreign bank to maintain records of the owners of the foreign bank and to maintain the name and address of an agent of the foreign bank in the United States authorized to accept service of legal process for records regarding the correspondent account. US financial institutions that are unable to obtain the required information or assure themselves that the correspondent account is not being used to indirectly provide services to a foreign shell bank are required to cease transactions and close the account.

Regulations issued provide that a US financial institution can satisfy the requirements of sections 313 and 319(b) by obtaining a certification from a foreign bank.

USA PATRIOT Act Certification

In order to comply with USA PATRIOT Act requirements, State Street Bank and Trust Company, on behalf of all of its non-US branches and non-US affiliated banks, has prepared a Global Certification for use by US financial institutions that deem they require a PATRIOT Act Certification from State Street Bank and Trust's non-US branches or non-US subsidiaries.