Following this announcement, the US Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) announced its decision to issue a request for information (RFI) related to the existing requirements for banks and financial institutions under the Customer Identification Program (CIP) Rules.
This process is expected to collect a taxpayer identification number (TIN) for a client prior to opening an account. Usually, for a customer who is a US citizen, banks and financial institutions are required to collect a full Social Security Number (SSN). Throughout this initiative, the RFI is being used in consultation with staff from the Office of the Comptroller of the Currency, the Federal Deposit Insurance Corporation, the National Credit Union Administration, as well as the Board of Governors of the Federal Reserve System.
In addition, the requirement for banks and financial institutions to collect identifying information from a client prior to opening an account has been a long-standing component of FinCEN’s anti-money laundering program. The enterprise recognises the significant changes in technology and financial solutions that have taken place since the promulgation of the CIP Rule, and it will continue to find new ways to modernise the US anti-money laundering initiatives and counter the financing of terrorism regime.
Since the adoption of the new CIP Rule, the financial landscape has seen a significant optimisation in the process of customer-identifying information collection, as well as verification tools being available to banks and FIs. The RFI is set to inform FinCEN’s understanding in these areas,S as well as evaluate the risks, benefits, and safeguards if banks were permitted to collect partial SSN information from a client and use reputable third-party sources in order to obtain the full SSN prior before the account opening. In addition, the RFI will also remind banks of the requirement to collect identifying information and data from the user prior to the account opening process.
According to the official press release, the request for information also supports FinCEN’s ongoing efforts and strategy to implement section 6216 of the Anty-Money Laundering Act of 2020. This initiative requires FinCEN to identify regulations and guidance that might be outdated, redundant, or otherwise do not continue to promote a risk-based AML or CFT regime.
In addition, FinCEN will continue to strongly encourage all interest parties to submit written comments, as they will be accepted for 60 days following the publication in the Federal Register.
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