WHEN A BANK CLIENT USES A PRIVATE POSTAL ADDRESS, WATCH OUT !

Much has been been made of the fact that Americans who wish to protect their privacy, are flocking to private postal facilities, which are privately-owned and run shipping offices, complete with post boxes, where one can have mail sent. Although I understand the logic behind this trend, especially in light of the disclosures about widespread surveillance of Americans by their government, looking for terrorist activity, there is a problem with the use of private post offices: it can effectively hide the location of criminals involved in white-collar, as well as narcotics, crimes.

If a bank client wants to use a postal box, that is his or her option, but you need, for CIP purposes, a true residential address. Your compliance department should always check the listed address of a new client online, to insure that it is not a private postal facility. Here's how;

(1) Run the address through a search engine; many private postal facilities have websites.
(2) Use a map program, like Google Map. If you zero in on the building, you can generally learn whether it is a residence, or an office building. Many private postal facilities are located in freestanding buildings, or in shopping centers that are easy to identify.

When I, as a young lawyer, represented American, Canadian and French narcotics traffickers, operating in the United States, I saw that most of them availed themselves of private post offices. Some of them actually purchased these businesses, to serve as fronts, and I observed that many of the sellers were also, themselves, involved in criminal activities.

If you find that a client is using a private postal facility, I recommend that you conduct Enhanced Due Diligence immediately, to make sure that they do not pose an unacceptable risk to your bank.