Gene Lederer

U.S. Bank Verification Just Got Harder for Non-Residents—Here’s Why Your Paperwork Must Be Airtight on Both Sides of the Border. Fresh guidance first. On 18 Jun 2025 Treasury’s BSA Advisory Group doubled-down on faster data-matching and zero tolerance for sloppy KYC. Backdrop: FinCEN’s $1.35 B AML penalty on TD Bank last autumn pushed every risk team to raise the bar. • Address spotlight. Banks now mail “Verify Your Business Location” letters. A CMRA or P.O.-box-only address is no longer accepted—produce a lease, utility, or tax notice proving real space or the account enters review (non-response can also trigger a Suspicious Activity Report). • Two-step shutdown. Miss the first deadline and outbound transfers pause; miss the second and the account may be terminated—or a SAR filed. • 90-day KYC vault. Keep an EIN letter, ≤ 90-day bank/utility statement, supplier invoices, and marketplace settlements ready to upload within 48 hours. • Plan B matters. Maintain a secondary bank or PSP so payouts keep flowing if your primary account is frozen for review. • EIN & address sync. The address on your IRS CP-575 should match the “principal place of business” on file with your bank—and, ideally, the address in marketplaces like TikTok Shop that run their own checks. Reverse-engineer the address first, then layer in banking and marketplace profiles. • Inventory = ECI. Goods stored in U.S. fulfillment centers create effective connected income. Assume U.S. reporting even if the final tax bill is zero—file a protective 1120-F + 5472 (or treaty-based 8833) each year to avoid $10K-per-form penalties. • Cross-border ripple. If your bank profile lists a U.S. legal address and a home-country operating address, expect both tax agencies to ask who gets first bite of the profits—plan the treaty position before the letters arrive. Seen one of those location-verification letters yet? DM me if you or your clients need support building a bank-ready KYC stack that keeps funds—and tax records—flowing. #EcommerceExpansion #USbanking #KYCrules #USLLCtaxation This post is for general information only and is not tax or legal advice. Consult a qualified professional for guidance specific to your situation.

1

Exciting news! ICI is now an ABA Premier Partner, bringing our core evaluation and negotiation expertise to support banks nationwide. Together with ABA, we are focused on shared goals that help banks and communities thrive.    Read the full announcement here:  https://lnkd.in/eT9hr-j9.      #coreconsulting #abapremierpartner #coreevaluation #negotiations #bankconsulting #technologyconsulting #fintech #strategicpartner

5