Just curious how others monitor and track for aliens. Our core system allows for tracking nonresident aliens but doesn't really have fields established for resident aliens. Other banks I have worked had both. We are in the process of revising our CIP and tracking for aliens so I want to be certain we cover our bases.

Should we be identifying first if a person is or is not a citizen of the US? And, then second does it matter if someone is a resident or nonresident alien when it comes to monitoring under BSA? I know that there may be a distintion for tax reporting purposes, I'm just wondering about the BSA side.

Thank you in advance for the responses on this.

If you do a search of the term "resident alien" in the BSA Examination Manual you will find no reference to separate mitigtion factors in additional to all normal mitigation factors that all customers would be subjected too.

If you have a country of origin field, you can possibly use that to track your resident aliens. If you don't, perhaps you have customizable or "user" fields and you can use one for country of origin/citizenship.

Asking about national origin is prohibited by Reg B for credit transactions. Citizenship is Ok.