AML ALERT: FinCEN Permits Banks to Use Alternative Collection Method for Obtaining TIN

The U.S. Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) issued an order permitting banks to collect Tax Identification Number (TIN) information from a third party rather than from the bank’s customer. FinCEN issued this order in coordination with the Office of the Comptroller of the Currency (OCC), the Federal Deposit Insurance Corporation (FDIC), and the National Credit Union Administration (NCUA) (collectively, “the Agencies”). The order permits a bank subject to the jurisdiction of the Agencies to use an alternative collection method to obtain TIN information from a third-party rather than from the customer, provided that the bank otherwise complies with the Customer Identification Program (CIP) Rule. The TIN may be a Social Security Number (SSN), individual taxpayer identification number (ITIN), or employer identification number (EIN).

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Order: FinCEN Permits Banks to Use Alternative Collection Method for Obtaining TIN Information | FinCEN.gov