Getting Around ID & SSN Requirments

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Question:

How are banks getting around requiring government issued IDs and SSNs when opening accounts or cashing checks for non-customers? How could you avoid a violation if a transaction with one of these led to the need to file a CTR/SAR and you didn't have a SSN? Would an ITIN be acceptable when filling out the CTR?

Answer:

I'm not aware of anyone "getting around" this. Banks MUST have a TIN/EIN before opening any account (per CIP). Banks must also verify the 4 CIP ID requirements (name, address, DOB and TIN). If the bank is not doing this, it should be discovered at the next independent audit and regulatory BSA exam.

First published on BankersOnline.com 7/31/06