Scenario: We have a 10+years legal entity customer who has been 100% owner of his company. He has reached an agreement with a non-U.S. person to take funding, in exchange for 40% ownership of the company. Our CIP policy requires ID verification (Experian, Qualifile, etc.). This non-U.S. investor has an ITIN (verified) but no U.S. verifiable ID like a driver's license, etc. So at the point where our customer takes funding, he/we will be violating our CIP policy by keeping the account open. Easy answer: close the account. Harder question: what about the loan the legal entity has with us?

Has anybody else come across something like this? And has anybody amended their CIP policy to address something like this?

A passport and the passport number is more than sufficient for CIP purposes unless for some reason your policy doesn't allow this.