Customer Identification Program (CIP) Under the United States of America Patriot Act

What is required of Non-U.S. Persons when opening a U.S. bank account?

 The CIP rules require financial institutions to apply certain identity verification procedures when a customer opens a new account. An “account” is defined as a formal arrangement established to provide ongoing services. Given this definition, the law applies to traditional types of accounts such as a checking, savings, certificates of deposit, as well as loans and other extensions of credit. The law does not apply to incidental relationships such as the occasional purchase of a money order, traveler’s check or a wire transfer.

The CIP rule also define the following:

(a) “customer” means any person seeking to open a new account and any person who will be signatory on the account at the time the account is opened or is added as a signatory after the account is opened.

(b) “person” is defined in the law and includes individuals, corporations, partnerships, trusts, associations, etc. This includes not only persons opening an account, but also includes any signatory on an account, such as an authorized agent for a business entity.

(c) “U.S. person” means a U.S. citizen or a legal entity established or organized under the laws of a State or the United States

(d) “Non-U.S. Person” means a person that is not a U.S. person.

(e) “account” is defined as a formal arrangement established to provide ongoing services. Given this definition, the law applies to traditional types of accounts such as a checking, savings, certificates of deposits as well as loans and other extensions of credit.

A New Account Relationship includes deposit and lending functions. Both are considered account relationships under these guidelines.

Customer Identification Requirements

The Bank requires anyone opening a new account relationship, or anyone added as a signatory to an account, to provide, at a minimum, the following information and to form a “reasonable belief” that the true identity of a customer is obtained. Included in this list is the acceptable identification required on all new account relationships, and any added signatory to an account:

 Individual Non Business Requirements:

  • Name
  • Date and place of birth
  • Residence address and mailing address if different (PO Box alone will not be acceptable)
  • If the individual is a U.S. person, the individual’s social security number. If the individual is a non-U.S. person all of the following that the individual possesses (minimum of one required): a U.S. taxpayer identification number; a passport number and country of issuance’ and alien identification card number; number and country of issuance of any other government-issued document evidencing nationality or residence and bearing a photograph or similar safeguard.
  • Official issued identification number (e.g. Social Security Number, Employee Identification Number or Individual Taxpayer Identification Number)
  • Current Drivers License (photograph required)
  • Current Armed Forces Identification (photograph required)
  • Valid Passport (photograph required)
  • Current Alien Identification (current photograph required)
  • Valid Social Security Number
  • Valid Employee Identification Number

Each bank will have its own policies and procedures drafted to comply with the requirements above. Most institutions choose to draft policies and procedures more strenuous than those required by law.

The following is examples of additional information that might be required:

  • Secondary ID (photograph not required Credit or Debit Card)
  • Proof of Address (Title, Lease, or Utility Bill)
  • Account Opening Process be done in person and originals of documentation be viewed
  • If the account owner is a non-U.S person without a U.S. ITIN then an IRS Form W8-BEN will be required