BSA/AML, CIP: Social Security Numbers
Printer-friendly VersionQuestion:
We are working on CIP and this question was brought up; What reg/rule says you must require a social security number to open an account? What about aliens? Can we open a non-interest bearing deposit account or loan without a US taxpayer identification number if we can verify their identity otherwise?
Answer:
Actually, the BSA has always required that you TRY to get the taxpayer ID number. But you could keep a list of those that didn't comply.
Look at 31 CFR 103.121(b)(2)(i)(4). For US persons, a TIN is required. For a non-US person, the number may be a TIN, passport number, alien identification card number or number and country of issuance of any other government-issued ID.
Look at 31 CFR 103.121(b)(2)(i)(4). For US persons, a TIN is required. For a non-US person, the number may be a TIN, passport number, alien identification card number or number and country of issuance of any other government-issued ID.