As for verifying the TIN, your CIP may require that you review an IRS document (or you could be real specific and require that you see a copy of the assignment letter). But the regulation doesn't require specifically that you verify the TIN. You must satisfy yourself as to the identity of the customer.
This you can do in a number of ways, including getting copies of documents, etc. If you wish to verify TIN, I cannot recommend requiring the customer supply a copy of the TIN assignment letter. That could be with the business's accountant or attorney, or squirrelled away almost anywhere. But you might have success asking to see some form of IRS document such as a form 941 printed with the business's name by the IRS, or a tax return front page, or a deposit booklet. I'm sure the customer could obtain a copy of the assignment letter from the IRS, but aren't you asking a bit too much here? After all, CIP is not supposed to make it difficult for honest people to open bank accounts!
As for attorney Smith. First of all, the TIN was assigned by the IRS, not the state. TINs are assigned to sole proprietors who must pay employees. If he's using his own name, he doesn't need a trade name or fictitious name certificate. All he needs is his license to practice law. You could ask for a copy of that.
John S. Burnett
Fighting for Compliance since 1976
Bankers' Threads User #8