Archive Links

Consumer Archive
CU System Archive
Market Archive
Products Archive
Washington Archive

News Now

Washington
FinCEN provides flexibility on CIP issues
WASHINGTON (1/13/10)--The Financial Crimes Enforcement Network (FinCEN) in a recent letter advised a financial institution whose customers cannot meet existing customer identification (CIP) requirements due to their participation in state-run address confidentiality programs (ACP). In the letter, FinCEN has determined that that customers who participate in a state-run ACPs “shall be treated as not having a residential or business street address and a secretary of state, or other state entity serving as a designated agent of the customer consistent with the terms of the ACP, will act as another contact individual for the purpose of complying with FinCEN’s rules. Therefore, the financial institution will collect the street address of the ACP sponsoring agency for purposes of meeting its CIP address requirements.” FinCEN addresses a situation in which a customer of a financial institution is “having difficulty establishing accounts or changing their address to the post office box that has been assigned to them” by state authorities. Many of these individuals taking part in these ACPs are victims of crimes and are seeking state protection. Under the Bank Secrecy Act, financial institutions must “implement a CIP that includes, at a minimum, risk-based policies and procedures that enable the [financial institution] to form a reasonable belief that it knows the true identity of its customers.” This relationship is usually established through the filing of a residential or business street address. In the event that there is not a valid business or street address to file, the BSA allows customers to provide the residential or business street address of a close relative of other personal contact. For the full FinCEN letter, use the resource link.
Other Resources

RSS print
News Now LiveWire
Thanks for following our tweets on the NCUA's #listeningsession.
7 hours ago
RT @IllinoisLeague: Mike Daugherty, CEO, Community Plus FCU: I'd like to you to reconsider your repeated 'No's' #listeningsession #fixRBC h…
8 hours ago
CU says definition of complex CU needs to be reviewed, and not just based on asset size. NCUA: We are looking at that. #listeningsession
8 hours ago
NCUA says lots of resources go 2 examiner training,but there's much turnover.Invites ideas on how to improve exam training.#listeningsession
8 hours ago
CU tells NCUA that more benefit could be gained by better examiner training than imposing this "unnecessary" RBC system at #listeningsession
8 hours ago