A. New Accounts. In order to detect any of the red flags identified above associated with the opening of a new account, city personnel will take the following steps to obtain and verify the identity of the person opening the account:
1. Require certain identifying information such as name, date of birth, residential or business address, principal place of business for an entity, driver’s license or other identification;
2. Verify the customer’s identity (for instance, review a driver’s license or other identification card);
3. Review documentation showing the existence of a business entity; and
4. Independently contact the customer.
B. Existing Accounts. In order to detect any of the red flags identified above for an existing account, city personnel will take the following steps to monitor transactions with an account:
1. Verify the identification of customers if they request information (in person, via telephone, via facsimile, via email);
2. Verify the validity of requests to change billing addresses; and
3. Verify changes in banking information given for billing and payment purposes.