A CTR was generated at our FI, and during the secondary review process it was discovered that the ID on file for the customer is expired. Staff have been attempting to contact the customer in order to get updated ID info but so far have had no luck in getting a return call. Obviously this is something that should've been noticed at the time of the transaction by the teller. That problem notwithstanding, what are we looking at if the customer doesn't come in to update their ID before the filing deadline for the CTR?

What does an expiration date on an ID on file have to do with identifying the customer? Where does an expiration date go on a CTR?

I wasn't certain it would have an impact, Randy, and in my searching for info I came across an (admittedly) old BOL thread that had me thinking it was worth a check.

The referenced thread notes that the ID was expired at the time the account was opened meaning that the bank had not formed a reasonable belief that it had identified its customer.

If your institution has already formed a reasonable belief that it identified the customer because the ID was valid at the time the account was opened, then as Randy stated, enter the ID number, state and country of issuance that you have and move on.

Thanks a bunch guys!

Another Anon:
50% of our CTR reported customers have expired DL's. Just sayin'.
But we know who they are. It is a good idea though to ask them if their address is current - because that does go on the CTR.

BrianC ...I took Latin in HS, thanks! Good stuff.

Another anon: Is there a document from FinCEN or another agency that says we don't need an unexpired license if we have already verified our customer?

The instructions???

Acceptable forms of identification include driver’s license, military or military/dependent identification card, passport, state issued identification card, foreign cedula card, non-resident alien identification card, or any other identification document which contains name and preferably address and a photograph and is normally acceptable by financial institutions as a means of identification when cashing checks for persons other than established customers.

The bigger elephant in the room is: why are you using a DL that's "on file"?

Assuming this was a teller transaction (?), shouldn't the staff be asking the conductor for an ID at the time of transaction?

The instructions again?


Acceptable identification information obtained previously and maintained in the financial institution’s records may be used. For example, if documents verifying an individual’s identity were examined and recorded on a signature card when an account was opened, the financial institution may rely on that information.

Isn't the key though "Acceptable identification information"?

Is an expired DL considered "acceptable"?

I opened an account 10 years ago at the bank. My bank has my identification information used at the time of account opening on file and it was acceptable at that time. I don't have to update it, as my identity has not changed. You don't record an expiration date of the identification document used on the CTR.

We actually talked about this topic (briefly in a Q&A) this week at the BSA/AML Top Gun conference. Beyond the instructions Randy provided, you can always call FinCEN for their insight, which seems to consistently say that an expired DL due to identifying/verifying a customer previously is okay. In other words, if you are worried about it, call FinCEN and keep a record of what they tell you so that you can show your examiners in the event they try to bring this up.

Here's a question though:

A few years back, our state changed our drivers license numbers. After years of having mine memorized, I had to learn a new one. A moot point.

What I'm getting at is: assuming all of the above is true, that we can just take a DL number that's one file, are we in violation of the DL NUMBER is incorrect, or no longer valid?

If you are taking an ID number on file how are you using it to identify the individual?

From the CTR instructions. Whether or not that identification document is now expired is irrelevant.


Acceptable identification information obtained previously and maintained in the financial institution’s records may be used. For example, if documents verifying an individual’s identity were examined and recorded on a signature card when an account was opened, the financial institution may rely on that information.