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Does an address on a driver's license need to match an address submitted on the beneficial ownership certification form?

An auditor cited my bank for a violation for using the business address of the beneficial owners listed on the beneficial ownership certification form. In the process of verifying the identity of the individuals listed, the bank received copies of their driver’s license, which listed their home addresses, not the business address. The auditors cited the bank because the address on the driver’s license did not match the address on the certification form. Was the auditor correct?

No. The law does not require that the information on the identification document and the certification form match. Moreover, it does not mandate use of the individual beneficial owner’s residential address.

In identifying the beneficial owner, at a minimum, banks must obtain the following identifying information for each individual beneficial owner of a legal entity customer:

  • Residential or business street address, or if the individual does not have such an address, an Army Post Office (APO) or Fleet Post Office (FPO) box number, the residential or business street address of next of kin or of another contact individual, or a description of the customer’s physical location. See 31 CFR 1010.220(a)(2)(i)(3).

In addition, banks may rely on the information supplied by the legal entity customer regarding the identity of its beneficial owner or owners, if it has no knowledge of facts that would reasonably call into question the reliability of such information. Assuming the business address is correct, that fact that an identification had a residential address does not appear to call that information into question.

Finally, banks need not establish the accuracy of every element of identifying information they obtain but must verify enough information to form a reasonable belief that they know the true identity of the beneficial owner(s) of the legal entity customer. The bank’s procedures for verifying the identity of the beneficial owners must describe when it uses documents, non-documentary methods, or a combination of methods. (July 2019)

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