News & Analysis as of

Customer Identification Program (CIP) BSA/AML Banks

Morrison & Foerster LLP

No Full TIN, No Problem: FinCEN Approves of TIN Verification Through a Third Party

On June 27, 2025, the U.S. Department of Treasury’s Financial Crimes Enforcement Network (FinCEN) issued an order (Order) allowing banks,[1] and their subsidiaries, subject to the jurisdiction of the Office of the Comptroller...more

Skadden, Arps, Slate, Meagher & Flom LLP

The CIP Rule Gets an Upgrade: What Banks and Fintechs Need to Know About the New Exemption

Key Points - On June 27, 2025, the Federal Deposit Insurance Corporation (FDIC), the Office of Comptroller of the Currency (OCC) and the National Credit Union Administration (NCUA) exempted supervised banks and credit...more

Troutman Pepper Locke

Strengthening Compliance: Lessons From the OCC's Consent Order With Patriot Bank — Payments Pros – The Payments Law Podcast

Troutman Pepper Locke on

In this episode of Payments Pros, host Carlin McCrory discusses a recent consent order between Patriot Bank and the Office of the Comptroller of the Currency (OCC) following a $27 million loss. The order addresses unsafe...more

McGlinchey Stafford

BSA, OFAC, KYC, and CIP – What do they mean to me? [More with McGlinchey, Ep. 29]

McGlinchey Stafford on

The Bank Secrecy Act (BSA) and parts of the U.S. Patriot Act’s Office of Foreign Asset Control (OFAC) requirements have seemingly similar goals: to prevent money laundering and the funding of terrorist activities. Yet a...more

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