The answer should be dictated by your CIP/CDD Policy and Procedures.
As noted on the model beneficial ownership form, FinCEN allows for the identification of foreign individuals as follows:
What information do I have to provide?
This form requires you to provide the name, address, date of birth and Social Security number (or passport number or other similar information, in the case of foreign persons) for the following individuals (i.e., the beneficial owners):
The form also notes. "In lieu of a passport number, foreign persons may also provide an alien identification card number, or number and country of issuance of any other government-issued document evidencing nationality or residence and bearing a photograph or similar safeguard."
Since you are required to verify the identity of beneficial owners, your procedures must state what type of foreign documents you are will to accept.
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