We have an individual that is a member of the Kingdom of Heaven. He is not a customer of ours but he is coming into our bank to cash on us checks. If you aren't familiar with this group, they are extremely anti-government. It is based out of Stayton, Oregon. In order to get an ID from the Kingdom of Heaven, they have to send in their state issued driver's license. They make up their own license plates for their cars, passports, birth certificates, etc. In regards to the individual in question, we don't know his real name only his Kingdom of Heaven name. This person has been in the community for years, but we don't know (nor will he supply) his legal name.

My question is how should we ID these people and OFAC them? We have a policy that we will OFAC non-customers if they cash on us checks over a certain threshold.

Would you let your bank cash a check like this when the presenter can only provide you a Kingdom of Heaven ID?

Our Bank would not based on CIP and Check Cashing Policies and Procedures. They must present a government issued ID (Driver's License, Non-Driver's ID, Passport), etc., or a Military ID, or in rare instances for the elderly, we would accept a Medicare card and 2nd form of identification. I would say that you would need to follow your policy, but I do appreciate the information. I am not familiar with this group, nor do I hope to ever be!

It really depends on what your CIP policy states. I would not allow this person or any person for that matter, to cash a check if they didnt have the proper ID which my Bank policy mandates.

While I havnt reviewed your Bank's CIP policy, I would be willing to wager that it doesnt stipulate a "Kingdom of Heaven" ID as an acceptable form of ID.

Cashing a check does not trigger CIP requirements; your CIP requirements do not apply to check cashing unless you have explicity indicated that they do.

Although it does not make any sense to me, banks are oftentimes more liberal in their ID requirements for cashing checks than they are for account opening; i.e. if you want to accept ID from a fantasy organization to cash a check when you would not accept it for opening an account, you may do so.

OFAC checks on payees are a function of policy, not a legal requirement. However, if you accept fantasy ID, you geld your OFAC check in violation of your own policy. So, back to square one.

Your bank should (not must) have written identification standards for check cashing. Your concern is not with the payee's beliefs, you have no contract with the payee. Your concern is with your customer; i.e. the person who wrote the check. I suggest you contact the customer who is issuing checks to this person and say that from now on your ID requirements are...