Government Agents/Employees Exempt from CIP?

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Question:

Are government agents or law enforcement employees exempt from providing their personal information for CIP when they open accounts?

Answer:

Determine who the customer is. If you are opening an account for a unit of government, the unit of government is your customer and is exempt from CIP regulatory requirements. However, your bank's CIP may call for certain verification steps with regard to the government unit, regardless of the regulatory exemption. If your CIP also mandates that you obtain identity information from the agent/employee opening the account, it should make allowances for these situations and permit the individual to provide information from a government-issued ID rather than the standard SSN, DOB and residential address normally required. If the account is being opened for the individual, who happens to be a government agent or employee, that's your customer and there are no special handling exceptions in the CIP regulation for such accounts. You must obtain the same four items of personal identifying information that you obtain from all other individual customers.

First published on BankersOnline.com 11/17/08