EDD Requests for Information (RFI)


These FAQs are meant to serve as guidelines for answering client questions with regard to recent communications that have been sent to a large number of our account holders, requesting specific information. If there are further questions not addressed in this guide, please contact the EDD department.

For All Accounts:

Is this a legitimate email?

Yes; we recently sent out communications to clients requesting that clients update specific data and documentation.

Why has the client received this notification?

We are conducting a routine review of our clients for the purpose of ensuring that we maintain accurate and up to date information and conduct due diligence on clients from places or of type that present heightened AML risk. As a regulated financial institution, we are required to “know our clients”, and this is part of that effort.

Is updating this information required?

Yes; all clients who have received a notification are required to provide the requested information.

What is Source of Wealth?

Source of Wealth means any way in which the client has derived their wealth. Examples include employment income, business income, property sale, inheritance, etc. A client’s sources of wealth should add up to 100%.

What documents are acceptable to prove Source of Wealth?

The documents we provided include a list of what you can submit to confirm your source of wealth. Each source of wealth must be accompanied by supporting documentation (e.g., a bank statement for employment income, a bill of sale for property sale, etc.).

For Org Accounts:

Why is beneficial ownership information required?

Under US regulations, we are required to collect information about an organization’s beneficial ownership. It is also part of our obligation to “know our clients.”

What is a beneficial owner? How is that different from a regular owner?

A beneficial owner refers to the actual people who ultimately own the entity. This differs from regular owners, who could be a combination of other businesses, trusts, custodians, etc. Under relevant regulations, we require any entity that is an account holder to identify any natural person who owns 10% or more of the entity. We then need to verify those peoples’ identities through identification verification documents and confirm their sources of wealth.

Do I need to complete the Ultimate Beneficial Owner form if I indicated on the Certification of Beneficial Owners form that there are no 10%+ owners ?

No – you do not have to complete the Ultimate Beneficial Owner form if you have certified there are no 10%+ owners.

For Casffis, IBrokers, Collective Investment Vehicles, And Hedge Funds:

What is a Wolfsberg Questionnaire?

The Wolfsberg Questionnaire is an Anti-Money Laundering (AML) Questionnaire designed by the Wolfsberg Group, which aims to provide a standardized overview of a financial institution's AML policies and practices.

*The form must be completed in its entirety and dated within the last 12 months.*

Why do I need to provide one?

The questionnaire is to help ensure that we know the organization implemented certain standards and practices associated with preventing money laundering, terrorist financing, and other financial crimes.

If the business is a hedge fund, we are seeking a completed Wolfsberg Q from their fund manager/investment advisor.

Is there a link to the Wolfsberg Questionnaire form?

Yes, the blank form is available to download in Account Management – please review the document task. You can also download the form here:


I am being asked to submit documentation regarding Fund Status. What documentation do I need to submit?

Please provide a proof of existence document for the fund, and proof of regulatory status for the fund manager and the fund administrator.

For Foreign Banks:

Why do I need to provide a Foreign Bank Certification?

Under the USA Patriot Act, any foreign bank that maintains a correspondent relationship with any US-based bank or broker/dealer must provide a foreign bank certification.

*The form must be completed in its entirety and dated within the last 36 months.*

What is the purpose of a Foreign Bank Certification?

The purpose of the foreign bank certification is to help ensure that the bank is complying with all required US regulations with regards to money laundering, terrorist financing, and other financial crimes.