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The recently released SBA Interim Final Rules can be viewed by clicking the link below. One interesting part of the attached SBA release deals with BSA/AML compliance. Section II on page 22 discusses the requirements for all lenders to identify and verify their PPP borrowers’s identities and if the borrower is a company, following any applicable beneficial ownership information requirements. Lenders should understand the nature and purpose of their customer relationships to develop customer risk profiles.

A Possible Future Problem: Given the millions of applications received and to be received, “knowing your customer” in all cases will be difficult. However, this most likely will be required in the future by the FDIC and other bank examiners and could result in a lot of costly BSA/AML re-work. Most banks are limiting applications to bank customers for just this reason possibly making it difficult millions of small businesses to apply.

PPP Interim Final Rules

Small Business Owner’s Guide to the CARES Act