Been searching to find out if this is a valid ID to use for CIP on a resident alien. Possible customer has been here since 2012 and has misplaced their passpost. Can I use an I-94 Form in place of that?

Please help!!!

Sorry passport...

Where's the photo on a I-94 Form?

"has misplaced their passport": Then they have some serious problems and need to get to their consulate immediately. Tell them to come back after they get their replacement.

They say they are refugees the was the only thing given to them. They have a SS card and a permanent card.

^^^^^^^^
this

I would not think that I-94 Form is mentioned in your board approved CIP as well.

I would not accept anything but the passport.

If they have a permanent resident card, why is there a need for a passport unless it is required by your own CIP and a permanent resident card cannot be used as primary documentary identification. Regardless, you can only use what your Board has approved in your internal CIP as acceptable, there cannot be exceptions.

The passport is required in our CIP policy and no edAduit it is not mentioned in our policy. I've never heard of it.

Admittedly I am very conservative in these situations, but CIP isn't an area where I like to wing it or make exceptions.

Ok so update on this topic. We have since opened up 5 acct for these refugees. They are required to provide me their I-94 form, driver's lic, permanent resident card and their SS card. They are coded as resident aliens and I'm wondering how I would risk rate them.

Habitat is building them a house, they are responsible for the closing costs which they have a year ti raise plus they have to help with construction on their house as well as their fellow neighbor. They have to open the acct with $75. My system has already rated them as a medium risk. At this time I'm not sure if I should keep them that way or change them to low for now.

Any suggestions?

If your CIP requires a foreign passport or I-94 documentation for a resident alien (green card in hand) then its author was sorely confused and the program needs to be revised. A resident alien has a right to be in the U.S. regardless of her country of origin and she may no longer have a current foreign passport.

Risk ratings are subjective and are entirely an internal matter. While you may be required to produce a list of non U.S. persons in an expanded BSA examination, there is no assumption regarding the appropriate level of AML risk they represent.

"there is no assumption regarding the appropriate level of AML risk they represent"

In a prior (foreign owned bank with a somewhat higher percentage of NRAs) we were informed by the regulator (OCC) that NRAs are of increased risk. Since we had an automated risk rating system and saw little to no increased risk we gave them 5 additional points and called it a day. It was not worth the effort of a fight since it was not going into the final report.