This method is not for shy compliance officers; one must be able to stand up to your relationship managers, who will say that the clients will not comply. Go to your board of directors and override their objections. Your bank does not need a massive fine for failing to identify the owners of a corporate client who later launderers millions of dollars through your bank.

• First, require on all new corporate accounts a letter, signed by a partner of the law firm that formed the corp, listing all officers, directors AND shareholders. Lawyers have licenses, are fully regulated, and they do not wish to lose their right to practise law by misrepresenting a material fact to a bank. This also forces them to issues the actual stock certificates, an important step that is often deliberately neglected when representing clients involved in illicit activities. Pull and review the Martindale-Hubbell law directory pages on the law firm to confirm the lawyer's status, or visit the local state bar association website. Have him also attach photocopies, both front and back, of the certificates issued, to the letter, and reference the same in the text.
• Second, have bank counsel prepare a form affidavit, which will be sworn to by the client in the presence of a Notary Public in your bank (not outside by a strange Notary). It will list the physical address, affirm the client's ownership of the corporation, state that he or she has no present intention of transferring ownership to another, and will also name the specific purpose of the corporation, such as type of industry.  It will also state that affidavit is being given to induce the bank to commence an account relationship. I thought of suggesting some appropriate language to include based upon my perspective, but your counsel is better familiar with the laws of your state, and is best qualified to prepare the affidavit.

You may judge these measures harsh, but I know from personal experience that anything else opens the door of opportunity for money launderers. If you are serious about really identifying beneficial owners on a level that would satisfy not only regulators, but also law enforcement, consider these steps.