Introductory BSA/AML Examiner School, Providence, RI

One or more of the following: • U.S. TIN. •

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Passport number and country of issuance. • Alien Identification Card number. • Number and country of issuance of any other government-issued document evidencing nationality or residence and bearing a photograph or similar safeguard.

Management is authorized to establish procedures to obtain other types of information from customers seeking to open new accounts that are consistent with industry best practices as well as safe and sound operations. The CIP regulation allows an institution to establish procedures for opening an account for a customer that has applied for, but has not yet received, a TIN. In this case, management must include procedures in the CIP to confirm that the TIN application was filed before the customer opens the account, and to ensure that the bank obtains the taxpayer identification number within a reasonable period of time. In the absence of a specific regulatory definition of “reasonable period of time”, the bank will allow a period of 60 days from the date an account is opened for a customer to obtain a TIN. Procedures will be established to monitor that a TIN is ultimately received, and to close the account if a TIN is not received within 60 days. Verification Methods The timely, accurate verification of a customer’s identity is of significant importance to both the financial institution and the customer. However, depending on the types of documentation provided and detailed, whether the customer was present, and when the account was opened will impact the verification options and time frames. Ideally, customer identity should be verified at the time the account is opened. If verification at the time of account opening is not possible or practicable, management must implement procedures to monitor for completion of the verification process, and may wish to consider restrictions on the customer’s use of the account (such as limiting access to the account or delaying issuance of access devices such as checks and debit cards until identity has been satisfactorily verified). Procedures must also be established to address situations where the identity of the customer cannot be satisfactorily determined. Verification through Documents The CIP procedures must provide specific directions for actions to be taken to verify identity through the inspection of documents obtained from persons seeking to open new accounts, including primary and secondary forms of ID which are acceptable and forms of ID that are considered unacceptable. In general, acceptable ID will include: • For an individual, an un-expired government-issued identification document evidencing nationality or residence and bearing a photograph or similar safeguard (such as a driver’s license or passport). • For a person other than an individual (such as a corporation, partnership, or trust), documents showing the existence of the entity, such as certified articles of incorporation, a government-issued business license, a partnership agreement, or trust instrument. Verification through Non-documentary Methods There may be new account opening scenarios, whether personal or business, in which verification of customer identity through the inspection of documents alone is not possible or sufficient. In situations that pose higher levels of risk, such as opening an account for persons who cannot present adequate identity documents or when the account is not opened in a face-to-face transaction, management will establish procedures for verification of the customer’s identity without, or in addition to, the use of identity documents. Heightened risk may call for the use of a combination of documentary and non-documentary verification methods. Examples of non-documentary verification methods the bank may utilize include: • Comparing customer-provided information against fraud and/or bad check databases. • Comparing information with a trusted third-party resource such as a credit reporting agency. • Comparing information to publicly available records and databases. • Contacting the customer after the account is opened. • Checking references. • Obtaining a financial statement and then checking the validity of the statement. • Checking prior financial institution account relationships.