My frustration with this is that we have been given the responsibility to identify red flags, but our tools are limited in the area of confirmning the TIN. I've been told that as banks we can sign up with the 'employment' verification system at the Social Security Administration, however in my investigation of that it seemed to be very clear that it was only available for the used connected with employment.
Does anyone have experience with this process? Our current method doesn't provide a definitive answer for us, it merely gives other people that may be associated with this. For BSA purposes and ID theft purposes, I would sure like stronger tools.