Legitimate Customers with No SSN
by Barbara Hurst, BOL Gurus BIO AND CONTACT INFO QUESTION: How do we deal with people who want to open accounts and have no social security numbers - such as the Amish people - especially if we have to file a CTR?
ANSWER: FinCEN, early on, gave us instructions on what to do about the Amish and those that have no social security numbers as far as filling out CTRs. I'll be detailing those instructions in the next issue of the HOTLINE. In the meantime, as far as opening an account for a person with no SS number, you can use the same identification you would if you were cashing a check or making a loan. Organization membership cards, invoices or statements in the mail to their address, verification with customers who may have prior knowledge, a geographic location that is connected to the name being given, even physical verification of the location by going yourself to the address given is not out of the question. Any means you can use to identify. In most cases, the person is related to someone with whom you are already doing business. That makes your life a lot easier!
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