In the past, I attended seminars led by Ken Golliher in which he advised us that if a CTR was filed on an Amish customer we were to put "Amish" in the Identification field for the individual. There is also an old article on this site (www.bankersonline.com/articles/109313) that says the same thing. Have there been any updates to this or is it still valid guidance?

These instructions apply to the legacy FinCEN CTR 104 in the references to Section A & B.

For the current electronic form, there are a some critical fields where you will be checking the 'unknown' box (e.g. Tax ID number.) For the identification field, selecting "Other" and entering "Amish Customer" would be the logical derivation from these legacy instructions.

As noted in the article, your CIP, CTR and SAR procedures should cover these groups if you are providing services to them.

Since 2003, banks have been required to obtain an SSN for U.S. persons opening an account. I've been told that the Amish do, in fact, have Social Security numbers because they need them to pay income taxes (and now, to open a bank account), they just don't participate in the Social Security system.

The customers in question have social security numbers on file, we just don't have any traditional identification like a drivers license for them to enter in item 20.

We also list identification as Amish customer. All our Amish customers have social security numbers.
We have never been questioned by examiners.

Of course, as with most religious groups, there are those people who may in fact have a state-issued ID or driver's license. You can't assume.

We've never been questioned on this either until a recent BSA audit. We used a firm we've never worked with before and have had a lot of "interesting" things come up.