Bank Secrecy Act/Anti-Money Laundering: Customer Identification Program Tax Identification Number Alternative Collection Method

Summary

On June 27, 2025, the Office of the Comptroller of the Currency (OCC), the Federal Deposit Insurance Corporation (FDIC), and the National Credit Union Administration (NCUA) (collectively, the agencies), with the concurrence of the Financial Crimes Enforcement Network (FinCEN), issued an order granting an exemption from a requirement of the Customer Identification Program (CIP) rule implementing section 326 of the USA PATRIOT Act, 31 USC 5318(l). The requirement is related to a bank obtaining taxpayer identification number (TIN) information from its customers.

Highlights

The order

• applies to all accounts at all banks (and their subsidiaries) subject to the agencies’ jurisdiction.
• provides an exemption from the requirement for these banks to obtain TIN information from customers before opening an account in the situations discussed in the order.
• permits banks to instead use an alternative collection method to obtain TIN information from a third-party source rather than the customer, provided that the bank complies with the CIP rule requirements for written procedures that
  • enable the bank to obtain TIN information before opening an account;
  • are based on the bank’s assessment of the relevant risks; and
  • are risk-based for the purpose of verifying the identity of each customer to the extent reasonable and practicable, enabling the bank to form a reasonable belief that it knows the true identity of each customer.
• is optional. Banks are not required to use an alternative collection method for TIN information.

Further Information

Please contact Eric Ellis, Director for BSA/AML Policy, Bank Supervision Policy, at (202) 649-5470.

James M. Gallagher
Senior Deputy Comptroller for the Office of the Chief National Bank Examiner

Related Link

• Exemption Order (PDF)