FinCEN Seeks Comments on Customer Identification Program Requirement

"...FinCEN recognizes the significant changes in technology and financial services that have taken place since promulgation of the CIP Rule, and we welcome comments from interested parties as we explore ways to modernize the U.S. anti-money laundering/countering the financing of terrorism regime."
FinCEN Director Andrea M. Gacki
"...FinCEN recognizes the significant changes in technology and financial services that have taken place since promulgation of the CIP Rule, and we welcome comments from interested parties as we explore ways to modernize the U.S. anti-money laundering/countering the financing of terrorism regime."
FinCEN Director Andrea M. Gacki

FinCEN solicited comment on the Customer Identification Program ("CIP") Rule requirement that banks collect a taxpayer identification number, from a customer who is a U.S. person, prior to opening an account. The Rule requires that banks collect a full Social Security number ("SSN") from a customer who is an individual and a U.S. person.

FinCEN is seeking input from banks and other interested parties regarding the CIP Rule’s SSN collection requirement, including potentially allowing banks to collect partial SSN information from the customer and using a third-party source to collect the full SSN. FinCEN said its Notice and Request for Information and Comment is intended to inform its "understanding in this area and assist [it] in evaluating the risks, benefits, and potential safeguards related to certain CIP Rule requirements applicable to banks."

Comments on the Notice must be received within 60 days of publication in the Federal Register.

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