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Can the bank use international passports and I-20 (student) visas as Customer Identification?

Our newly opened branch is across the street from a university and the bank anticipates that many international students will be asking to open accounts. May the bank rely on valid passports and I-20 (student) visas to open accounts? Our Customer Identification Policy (CIP) does not address this because the bank never contemplated a high volume of international students when it established its CIP policy.

If the bank’s policy does not indicate that it accepts international passports and I-20 visas, it should not accept those documents unless the board specifically approves an exception to that policy or until it revises its policy and its board approves the revisions. The law places the responsibility for BSA/AML compliance (of which CIP Is part) squarely on the bank’s board, and only the board can approve changes or exceptions to the bank’s BSA/AML policy.

(See #9 in the Transaction Testing section of the FFIEC Examination Manual, “A bank’s policy may not allow staff to make or approve CIP exceptions.”) (December 2019)

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