One of my primary concerns regarding banking an illegal alien is understanding how to validate the true identity of the individual.
Identifying aliens properly should involve review of government-issued documents such as passports, visas (when applicable) for NRAs along with U.S. issued Resident Alien cards for resident aliens. There are other documents which are useful and logical for aliens with permission to work, such as a Social Security card.
Whether you choose to utilize documents such as Matricula Consular Cards is up to the bank, but your procedures and policies should be clear to ensure you staff knows exactly what they are allowed to utilize to establish the identity of a non-U.S. person.
Questions to ask when deciding how you want to handle:
1) Will we bank non-resident aliens? If so, what will we accept as ID?
2) Will we bank resident aliens? What will we accept as ID?
3) Will we bank any individual that cannot produce required ID? If so how will they be identified?
4) If an alien is obviously working, but has no SSN, will we bank him/her?
5) Do we have process in place to follow up on expired W-8BEN's for NRA's with no U.S. TIN? Be sure staff is trained on how to docment NRA on W-8BEN.
6) Do we have appropriate fields to ID aliens in our database (country of origin, country of residency, ID documentation fields, W-8BEN expiration date, etc.)
7) Do we have processes in place to idenitfy customers subject to 1042S reporting?
Just a few things to think about.
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