We are getting ready to open a branch on a campus of a local university that has many international students attending. These international students do not have a SSN's. What documents can we accept that would satisfy CIP requirements? I'm assuming foreign passport/alien ID card and or school ID. Anything else?

What documents can we accept that would satisfy CIP requirements?

What ever you say that they are and as it is articulated in your board approved CIP policy. I'm sure that you have opened an account for a non-resident alien before?? Usually, it is nothing less than a passport from their country of origin. School ID's don't cut it, they are not government issued identification.

Thank you for your response. My institution has never booked an international student before so we are requesting the following information at the time that they apply for an account.

Full Name
Campus Address (determined by that College or University)
Campus or Cell Phone number
Unexpired Passport
I-20
Student VISA

I believe that by asking for this information, we should be covered from a CIP standpoint, since they are instructed by the Department of Homeland Security to carry their Passport, I-20 and VISA with them at all times.

As you contemplate that you are only opening accounts for students, a student ID would be a good form of secondary identification. (It should match the name on the passport and will have the benefit of being in English.) If an NRA does not have a student ID, perhaps it's not the type of account you are looking for...

A Visa is not a form of identification. At best, it's another form of secondary identification; i.e. it corroborates the passport. Note that there are 38 Visa Waiver countries. Citizens of those countries do not need a Visa when they are in the U.S. for business or tourism. I do not know how that affects students from those countries.

CIP requires you to get a number. If they do not have a U.S. TIN, you may accept the number assigned by their home government.

If the student does not have a U.S. TIN consider opening only non interest bearing accounts. It will save you a great deal of time and compliance responsibilities to the IRS.

Have the board revise your CIP before you start down this path. If I was on your board, the discussion would be robust.

And don't forget about PEP screening. International students present a potential risk of being a close relative of a political person in a foreign country.

That has already been discussed and I stressed that the OFAC piece of this puzzle is a MUST!!!

PEPs are not necessarily included on OFAC's SDN List.

^^^ - Correct, and there is no "list" of PEPs despite what many erstwhile vendors will tell you. Oh sure, you can get a list of the actual foreign officials, but a PEP also includes the close friends and family members, and in the case of state-owned institutions, the management officials of that institution plus close friends and family members.

With foreign students attending a university, you need to ask the student if his parents or relatives are government officials or management of any state-owned institutions. Ideally you should ask them to provide you with a copy of the forms they submitted to the university for acceptance, but you'll probably get a lot of push-back on that. In addition, you will probably not get any help from the university on that end as they typically have strict protocols on sharing any student information.

You may also consider holding off on the PEP question until you see what kind of money comes into the account. No joke, I did some consulting work at a CU connected with a large university that had a lot of foreign students, and it was NOT uncommon for these students to receive wires of $25,000 or more every month, and the "kids" would come in and withdraw thousands of dollars in cash. (The explanation given was that these were "rich" kids who were accustomed to having lots of cash for parties, to buy cars, clothes, and "whatever." smh) So if that should occur, then you immediately want to contact your account holder with the PEP questions.