If an individual from France wanted to open an account at your institution and they had a passport what would you record for the TIN? Would you require the individual to apply for ITIN or just use the passport number? There are differing opinions here, Surprise, Surprise.

After doing the research, the passport number is acceptable for the TIN. This raises another question, what would you institutions accept for verification. I have seen the debates over the passport but other than that what is available for the foreign customers?

I think that you have a wider problem for would-be customers offering a non-US passport as ID. How do you know that the passport holder is not a US permanent resident, or even a dual citizen, looking to evade taxes? Are you inadvertently opening a fraudulent account, or is the account opener concealing a bad credit record?

At very least you should look through the whole of the passport to look for a visa (in which case the owner may be a US permanent resident*), or a recent entry stamp.

* Visa recognition is a huge topic that would take more space than is available here to fully explain.

In this particuler instance, the individual is participating in a farm research project and is the guest of one of our well-established customers who has been conversing with this individual for a considerable amount of time. While I feel this case is legitimate, I do acknowledge that there will be those that aren't.

Due to our location (rural area), we have not had to deal with these types of issues in the past and therefore lack the experience of how to handle them. We are spreading into more urban areas and are trying to prepare for these issues in advance. However, sometimes they catch when you least expect it and are not completely prepared. We did cover this in our CIP but didn't expect to have it tested the first day. I did anticipate revisions and it looks like I need to get started.

Would anyone be willing to share their portion of the CIP dealing with Non-US Persons?

While not part of CIP, assuming the account pays interest, you will also need to have the customer sign either a W-9 or a W-8. That way the customer is certifying to you what their status is.

We have the same circumstances here. Our foreign person is from Austria and working for a well established customer.

Our CIP states that if the person is not a US citizen, we obtain one or more of the following: Individual taxpayor ID number, International passport number and country of issuance, Alien ID number, Country of issuance of any other government-issued document evidencing nationality or residence and bearing a photograph or similar safeguard.

Obviously, we also must have a W-8 on file.

Ironically, it seems we must have less ID from a foreign person than a US citizen...go figure!

Is the alien ID number people refer to for NRA the visa number? Shouldn't all NRAs have a visa (excepting Canadian citizens but including Mexican nationals), assuming that someone here for 90 days on business or pleasure with a visa waiver is not opening an account? Has anyone accepted an Employment Authorization Card from a Mexican national, and do they need a passport and visa?

Am I the only person who worries about individuals who are employees of "well established customers"?

What I am reading implies that the guard has been dropped, if only slightly, to accomodate the employee of the well established customer. Isn't this highly dangerous as it is well known that the easiest way for a conman to gain credibility is by associating with an innocent dupe.

I can see no reason to enforce anything less than consistently high standards of documentation for all would-be customers, no matter who they work for.

BTW It seems to me to be only one small step from opening an account for the employee of a well established customer to opening an account for a student of well established customer who operates a flight school! Tell me I'm paranoid and I'll point you to other events were extremely improbable.