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FinCEN seeks public comment for changing SSN requirements during customer identification
On March 29, FinCEN published a request for information (RFI) and comment in the Federal Register, in consultation with the OCC, FDIC, NCUA, and the Fed, to receive more information on the Customer Identification Program (CIP) Rule requirement. This announcement extended the comment period as the regulators explored how banks can better collect a customer’s social security number (SSN). Specifically, FinCEN sought information on the “potential risks and benefits” if banks were to be allowed to collect partial SSNs from customers, and then used a “reputable” third-party source to obtain the full SSN. FinCEN noted there has been “expressed interest” in permitting this practice. Written comments must be received on or before May 28.
FinCEN grants limited relief to casinos
On October 19, the Financial Crimes Enforcement Network (FinCEN) issued a notice that grants limited exceptive relief to casinos from some customer identity verification requirements regarding online gaming. Casinos are not subject to Customer Identification Program (CIP) regulations, which results in casinos not having the ability to rely upon non-documentary verification of a customer’s identity. As previously covered by InfoBytes, in 2020, FinCEN issued an interagency order granting an exemption from the requirements of the CIP rules for insurance premium finance loans extended by banks to all customers. According to the recent notice, a casino can use suitable non-documentary methods to verify online customers’ identification and “[t]he suitability or non-suitability of any particular method should be evaluated based on risk.” The notice also notes that a casino’s anti-money laundering program requires describing when the casino will verify identity by documentary methods, non-documentary methods, or a combination of both. This exceptive relief is effective October 19.