What identifying information must a bank collect from a customer under its CIP before opening an account?

A bank's CIP must include procedures for opening an account that specify the identifying information to be obtained from each customer. At a minimum, the bank must obtain four items from the customer before opening an account, subject to two exceptions (31 CFR 1020.220(a)(2)(i)(A)).

The four minimum items are:

• Name.
• Date of birth, for an individual.
• Address. For an individual, this is a residential or business street address. An individual without one may give an Army Post Office or Fleet Post Office box number, or the residential or business street address of next of kin or of another contact individual. For a person other than an individual (such as a corporation, partnership, or trust), it is a principal place of business, local office, or other physical location.
• Identification number. For a U.S. person, this is a taxpayer identification number. For a non-U.S. person, it is one or more of: a taxpayer identification number; a passport number and country of issuance; an alien identification card number; or the number and country of issuance of any other government-issued document evidencing nationality or residence and bearing a photograph or similar safeguard.

When opening an account for a foreign business or enterprise that does not have an identification number, the bank must request alternative government-issued documentation certifying the existence of the business or enterprise (note to 31 CFR 1020.220(a)(2)(i)(A)(4)(ii)).

The two exceptions:

• Taxpayer identification number applied for but not yet received: the CIP may provide for opening the account, but it must include procedures to confirm that the application was filed before the customer opens the account and to obtain the number within a reasonable period of time after the account is opened (31 CFR 1020.220(a)(2)(i)(B)).
• Credit card accounts: the bank may acquire the required identifying information from a third-party source before extending credit (31 CFR 1020.220(a)(2)(i)(C)).

This answer covers banks only. Verification of the information and recordkeeping are outside this answer.

Sources

1. 31 CFR § 1020.220(a)(2)(i)(A)-(C): https://www.law.cornell.edu/cfr/text/31/1020.220
2. 31 CFR 1020.220 (eCFR): https://www.ecfr.gov/current/title-31/section-1020.220

This answer is general information, not legal advice. Forteris is not a law firm.