News & Analysis as of

Customer Identification Program (CIP) FinCEN New Guidance

Ballard Spahr LLP

Financial institutions may rely on third parties for Social Security, Taxpayer Identification Numbers

Ballard Spahr LLP on

Banks and credit unions may now rely on third parties to provide a consumer’s Social Security or Taxpayer Identification Number, according to an order issued by the FDIC, OCC and the NCUA with the consent of the Financial...more

Bradley Arant Boult Cummings LLP

Hemp Banking – FinCEN Issues New Guidance Regarding AML/BSA Obligations

...On June 29, the Financial Crimes Enforcement Network (FinCEN) issued guidance (the “June guidance”) to “address questions related to Bank Secrecy Act/Anti-Money Laundering (BSA/AML) regulatory requirements” for providing...more

WilmerHale

Federal Regulators Clarify Bank CIP Obligations for Prepaid Cardholders

WilmerHale on

Banks and credit unions that issue reloadable, general purpose prepaid cards must apply Customer Identification Program (CIP) procedures to those cardholders, according to guidance issued by the federal banking regulators and...more

Troutman Pepper Locke

Banking Agencies, FinCEN Issue Guidance on Applying CIP Requirements to Prepaid Cards

Troutman Pepper Locke on

On March 21, 2016, the Banking Agencies, along with the Financial Crimes Enforcement Network (FinCEN), issued guidance to banking institutions on applying customer identification program (CIP) requirements when issuing...more

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