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Can a bank use driver's license or passport on file to open a business account if that CIP verification is expired?

If a beneficial owner has been previously identified in accordance with a bank’s Customer Identification Program (CIP) years ago and is now a beneficial owner on a new business account, must the bank obtain updated verification if the driver’s license or passport on file has expired? Question 7 in FinCEN’s Frequently Asked Questions Regarding Customer Due Diligence Requirements for Financial Institutions dated April 3, 2018, states that a bank may rely on the information it has on file, “provided the existing information is up-to-date, accurate, and the legal entity customer’s representative certifies or confirms (verbally or in writing) the accuracy of the pre-existing CIP information.”

No, there is no requirement to update documents the bank relied on to verify someone’s identity, even if the document relied upon originally has expired. (That this is not to say that a bank cannot update documentary verification.) Based on conversations with regulators and FinCEN, Question 7 is directed at updating addresses (or sometimes names), which can change. In contrast, a person’s identity does not change with the expiration of an identification document. Thus, the bank may rely on the previous identification verification as long as the verification document was valid and current at the time of verification. (March 2019)

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