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ID for the Patriot Act

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What forms of identification are acceptable for compliance with the Patriot Act?

The Patriot Act does not specify acceptable forms of identification. Rather, it charges the institution with collecting certain pieces of identifying information and verifying that information in accordance with risk-based standards established by the institution. Those methods can include both documentary and non-documentary verification methods. The bank has to do an assessment of risks posed by the types of customers, accounts, and locations where the bank is doing business, and, based on that assessment of risk, determine for itself what types of identification would be acceptable.

Since these requirements went into place several years ago, most established banks should already have a Customer Identification Program (CIP) in place that specifies acceptable identity verification methods and tools. The CIP should be reviewed periodically to ensure that the risk assessment continues to be valid, and the specified ID verification methods and tools are still current. If this relates to a new bank being formed, then the risk assessment and bank choosing the types of identity verification methods to include in its CIP is the way to go.

First published on 6/12/06

First published on 06/12/2006

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