As long as we satisfy the minimum CIP requirements can we require or limit the types of ID used however we want?

i.e. You must have a valid US DL/ID Card to open an account.

Yes. Your policy has certain implications about who you will and will not do business with, but you are entitled to make those choices.

To refine it a bit more closely, some banks require a U.S. taxpayer identification number. The CIP regulation only requires an identifying number and provides examples of foreign numbers that are acceptable. A decision to require a U.S. TIN has even more specfic implications than requiring U.S. ID; i.e. I can have U.S. ID, but still not have a U.S. TIN.

Requiring both U.S. ID and a U.S. TIN sends a pretty specific message.