FinCEN CTR Instructions - Does FinCEN address identification requirements?

Compliance > BSA > FinCEN CTR Instructions
Q:  Does FinCEN address identification requirements?
 
A:  Yes.  All individuals (except employees of an armored car service operating as an agent of the reporting financial institution) conducting reportable transactions for themselves or for another person, must be identified by means of an official document. Acceptable forms of identification include driver’s license, military or military/dependent identification card, passport, state issued identification card, foreign cedula card, non-resident alien identification card, or any other identification document which contains name and preferably address and a photograph and is normally acceptable by financial institutions as a means of identification when cashing checks for persons other than established customers. Acceptable identification information obtained previously and maintained in the financial institution’s records may be used. For example, if documents verifying an individual’s identity were examined and recorded on a signature card when an account was opened, the financial institution may rely on that information. In completing the FinCEN CTR, the financial institution must indicate on the report the type, number, and issuer of the identification. Statements such as “known customer” or “signature card on file” are prohibited and are not sufficient for report completion. The actual identifying information must be provided.
 
For casino customers granted accounts for credit, deposit, or check cashing, or on whom a previous CTRC or FinCEN CTR containing verified identity has been filed, acceptable identification information obtained previously and maintained in the casino’s internal records may be used as long as the following conditions are met. The customer’s identity is re-verified periodically, any out-of-date identifying information is updated in the internal records, and the date of each re-verification is noted on the internal record. For example, if documents verifying an individual’s identity were examined and recorded on a signature card when a deposit or credit account was opened, the casino may rely on that information as long as it is re-verified periodically. The actual identifying information must be provided. Statements that the identifying information is on file are prohibited.
 
This is addressed in the "FinCEN Currency Transaction Report Electronic Filing Requirements" guide, Attachment C, General Instruction #5.

The guide can be found here:  http://sdtmut.fincen.treas.gov/docs/FinCENCTRElectronicFilingRequirements.pdf

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