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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.
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