FinCEN Seeks Comments on Customer Identification Program Requirement

WASHINGTON-The U.S. Department of the Treasury's Financial Crimes Enforcement Network (FinCEN) is issuing a request for information (RFI) related to existing requirements for banks under the Customer Identification Program (CIP) Rule to collect a taxpayer identification number (TIN) from a customer prior to opening an account. Generally, for a customer who is an individual and a U.S. person, banks are required to collect a full Social Security number (SSN) from a customer. The RFI is being issued in consultation with staff at the Office of the Comptroller of the Currency, the Federal Deposit Insurance Corporation, the National Credit Union Administration, and the Board of Governors of the Federal Reserve System.

"The requirement for banks to collect identifying information from a customer prior to opening an account has been a long-standing component of a bank's anti-money laundering program," said FinCEN Director Andrea M. Gacki. "However, 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 recognizes that since the adoption of the CIP Rule there has been significant innovation in customer identifying information collection and verification tools available to banks and other financial institutions. This RFI will inform FinCEN's understanding in this area and evaluate the risks, benefits, and safeguards if banks were permitted to collect partial SSN information from a customer and subsequently use reputable third-party sources to obtain the full SSN prior to account opening. This RFI also reminds banks of the requirement to collect identifying information from the customer prior to opening an account.

In addition, this RFI supports FinCEN's ongoing efforts to implement section 6216 of the Anti-Money Laundering Act of 2020, which requires FinCEN to, among other things, identify regulations and guidance that may be outdated, redundant, or otherwise do not promote a risk-based AML/CFT regime.

FinCEN strongly encourages all interested parties to submit written comments. Comments to the RFI will be accepted for 60 days following publication in the Federal Register.