Another compliance person called me this morning and asked me if I keep a listing of individuals that we open accounts for that open the account with a matricula.

I said I do not currently do that and also I don't put them on my BSA "High Risk" listing.

Should I be including these accounts that were opened with matriculas (post 10-1-03, the CIP deadline) on a separate list or even on the BSA High Risk account listing that I currently have?

All responses appreciated.

We do not even accept matricula as an acceptable ID. They are not a realiable source of identification.

Every bank should make certain it can identify all non resident alien accounts. It would be reasonable to classify them all as high risk (subject to higher levels of monitoring), particularly those belonging to individuals from high risk countries or countries associated with certain money laundering typologies; e.g. Black Market Peso Exchange.

However, it not logical to consider accounts as high risk just becasue they used a certain type of ID. If a bank considers the Matricula to be of questionable value, it makes no sense that they accepted it at all.