Good afternoon,

What risks are associated with and compliance concerns should I be aware of, if we are to open checking accounts with debit cards for individuals with no SSN/ITIN, non-residents?

They have all other pieces of info that CIP would require for non-residents...

You must have an Identification number, which is:
(i) For a U.S. person, a taxpayer identification number; or
(ii) For a non-U.S. person, one or more of the following: a taxpayer identification number; passport number and country of issuance; 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." So Non-US persons may have other ID numbers.

Check with your card issuer - you might need an international card license to issue to non-us persons.

You'll probably want to review the Nonresident Aliens and Foreign Individuals section of the BSA/AML Manual.

Thanks for everyone's help.