Which of the following would not be a reasonable step when onboarding a new business investment account?

• A. Verify identity of the account holder
• B. FBI background check
• C. Screen against sanctions lists
• D. Establish a customer profile

Answer: (B)

Onboarding a business investment account hinges on applying basic AML due diligence: confirming who the business is and who controls it, screening for sanctions or restricted parties, and establishing a customer profile to inform ongoing monitoring and risk treatment. Verifying the identity of the account holder is essential to prevent fraud and ensure regulatory compliance. Sanctions screening protects the institution by blocking dealings with prohibited entities or individuals. Building a customer profile helps assess risk, including ownership structure, business purpose, and expected sources of funds, so monitoring can be tailored accordingly.

An FBI background check goes beyond standard onboarding practices. It is invasive, often impractical, and not typically required as part of routine KYC for ordinary business accounts. AML programs rely on identity verification, sanctions screening, and risk-based customer profiling to address money laundering risk, reserving deeper investigations for specific high-risk situations or regulatory triggers.