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#668663 - 01/19/07 03:55 PM Forgein Nationals and New Accounts
chell Offline
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Joined: Mar 2005
Posts: 27
How can you open a new non-interest bearing account for a forgein national individual who does not have a SS# and is not a resident of the US?

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BSA/AML/CIP/OFAC Forum
#668670 - 01/19/07 03:58 PM Re: Forgein Nationals and New Accounts chell
rlcarey Online
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rlcarey
Joined: Jul 2001
Posts: 83,226
Galveston, TX
With a passport.
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The opinions expressed here should not be construed to be those of my employer: PPDocs.com

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#668691 - 01/19/07 04:15 PM Re: Forgein Nationals and New Accounts rlcarey
chell Offline
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Joined: Mar 2005
Posts: 27
Would you also require a second form of identification number or is a passport or Matricular Consular Card sufficient?

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#668716 - 01/19/07 04:36 PM Re: Forgein Nationals and New Accounts chell
rlcarey Online
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rlcarey
Joined: Jul 2001
Posts: 83,226
Galveston, TX
That is totally up to the bank and based on their board approved CIP procedures.
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The opinions expressed here should not be construed to be those of my employer: PPDocs.com

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#668780 - 01/19/07 05:21 PM Re: Forgein Nationals and New Accounts rlcarey
chell Offline
Junior Member
Joined: Mar 2005
Posts: 27
We have some difference of opinions that the fourth element required by CIP to be obtain for a new account be a SS# or TIN. The conflict is that a forgein national will not have that and they aren't agreeing that the passport or matricular card is sufficient. Is it sufficeint in your opinion as long as it is unexpired and government issued with a picture?

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#668907 - 01/19/07 06:57 PM Re: Forgein Nationals and New Accounts chell
rlcarey Online
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rlcarey
Joined: Jul 2001
Posts: 83,226
Galveston, TX
From the CIP regulations:

(4) Identification number, which shall be:

(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.
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The opinions expressed here should not be construed to be those of my employer: PPDocs.com

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#669001 - 01/19/07 07:43 PM Re: Forgein Nationals and New Accounts chell
Ted Dreyer Offline
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Ted Dreyer
Joined: Apr 2001
Posts: 2,245
chell: The people at your institution are mixing two different things. The fourth item of information to be collected is the ID number, and Randy has provided the language from the reg on that.

That is not the same thing as getting a document for verification. For an individual you must always collect the required information: Name, physical address, date of birth and ID number. You then verify that customer's identity either with a document or by nondocumentary means or both. Collecting an ID number is required even if you don't get an ID document.

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