foreign nationals in another country where the church conducts its operations. They are not signers on the account. The business line called me to ask about CIP for the debit card holders. I told them the debit card holders do not meet the definition of customers, so this is not a CIP issue. However, it could be a fraud risk issue, so we may want to obtain some sort of ID for them, like a local drivers license or ID card. Did I get that right do you think?

Will you be screening the names of these customers for OFAC? I think this presents an OFAC and sanctions risk to you, depending on how you screen your customer base.

There is also the very real threat of money laundering or terrorist financing. Too many seemingly beneficent charities have been connected with AML and terrorist financing to simply assume that even a mission church, as much as you don't want to believe it could be involved, should get a "pass" on simply letting this proposal go unchallenged.

You need to know a lot more than the skeletal facts you have provided here.