DISPATCH CLASSIFICATION SECRET PROCESSING ACTION ACCUMULATED
TO
Chief, WH Division
INFO.
Chief of Station, JMWAVE
SUBJECT
AMTIKI-1 Trustee Accounts
ACTION PRESENTED: REFERENCES
REFERENCES:
A. UFGA-29508
B. UFGA-29614
C. JMWAVE-1613
D. DIR 83308
1. AMTIKI-1 has contacted the bank regarding the Social Security numbers requested and has been advised that, although the bank is not obligated to insist upon Social Security or other identifying numbers for these accounts, it does feel that AMTIKI-1 may ultimately be subjected to an inquiry from the Internal Revenue Service. Their reasoning is based primarily upon the fact that the accounts, while trust accounts for our purposes, are not true trust accounts in that no trust agreements are of record at the bank. (Trust agreements could not be signed, of course, since the individuals were not and are not available to sign.)
2. In order to protect AMTIKI-1 from any possible IRS investigation and, rather than pursue the matter further with the bank, for which we have no cleared contact, it is suggested that these accounts be closed out over a two or three month period and re-established at Headquarters through the appropriate DTEARN channels. If the accounts remain here, it will be necessary to prepare new signature cards for each account removing Humphrey O. TIMANUS as a signatory and adding a JMCOBRA asset as an "inside" trustee for control purposes, or to remove AMTIKI-1 entirely and establish the JMCOBRA asset as the sole trustee.
3. Please advise.
Distribution:
3 - Chief, WH Division