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#1238613 - 08/25/09 04:39 PM Expired ID
UTBPMOM Offline
Member
Joined: Sep 2005
Posts: 73
We have a long time member (1991) who only makes deposits to his account and uses his debit for withdrawls. So we have not had a real need to ask for ID. Well a recent request from him required the need to see his ID. The ID had been expired since 2000! He stated that he would not be able to obtain a new ID because he would get in trouble if he goes into a government agency. He also stated that INS would not renew his papers. What do we do? I was thinking SAR-but for what reason? We are a credit union so we can not just close his account.

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BSA/AML/CIP/OFAC Forum
#1238852 - 08/25/09 07:49 PM Re: Expired ID UTBPMOM
EdieT Offline
Member
EdieT
Joined: May 2009
Posts: 76
PA
Not providing acceptable ID when required violates the 26 RED FLAGS & the FACT ACT. Call FinCEN for guidance on the SAR.

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#1238869 - 08/25/09 08:08 PM Re: Expired ID UTBPMOM
Elwood P. Dowd Offline
10K Club
Elwood P. Dowd
Joined: Aug 2001
Posts: 21,939
Next to Harvey
You do not say what you needed his ID for or what expired ID he offered so there's not much to be said about that.

Not assuming any facts you did not offer, all I see is that the person may be in the country illegally. That is not a SARable offense. Some of the Mega banks treat illegals/undocumented workers as a target market and if they started filing SARs on them the little old data processing center in Detroit would be swamped.
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#1238998 - 08/25/09 10:15 PM Re: Expired ID Elwood P. Dowd
ACBbank Offline
Power Poster
ACBbank
Joined: Jul 2006
Posts: 4,344
New York City
I agree with Ken. I dont really see how you could file a SAR based on the situation you described.

That aside, what is your Bank's policy about ID? Most banks will request a new form of primary identification when they find out what they were relying on, has in fact, been expired.
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#1241888 - 08/28/09 11:19 PM Re: Expired ID UTBPMOM
UTBPMOM Offline
Member
Joined: Sep 2005
Posts: 73
THanks, the member presented an expired drivers license to have his bank card repinned. We could have used account information to verify him but we don't have updated government issued ID since the account opened.

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