Thanks. I was going through what I recalled on all this and I ran over here to see if I could get this posted before you answered, I came up with “know your client” for KYC. AML, I did not come up with but feel I should have been able to guess as the US FBAR is an AML law. A law passed on 1970 but had no penalty for noncompliance until I think 2009, that was then applied retro actively for 5 or 6 years.
If you are outside the US, what do/did your institution/s do in regards to US persons? In Japan, they report all transactions to the US despite FATCA’s $50,000 account balance threshold.
Thanks. I was going through what I recalled on all this and I ran over here to see if I could get this posted before you answered, I came up with “know your client” for KYC. AML, I did not come up with but feel I should have been able to guess as the US FBAR is an AML law. A law passed on 1970 but had no penalty for noncompliance until I think 2009, that was then applied retro actively for 5 or 6 years.
If you are outside the US, what do/did your institution/s do in regards to US persons? In Japan, they report all transactions to the US despite FATCA’s $50,000 account balance threshold.