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United States – A risk-sensitive application of the Customer Identification Programme In the United States, the RBA to the Customer Identification Programme (CIP) Rule under the Bank Secrecy Act (BSA) does not require a bank to establish the accuracy of every element of identifying information obtained. The bank must verify enough information to form a reasonable belief that it knows the true identity of the customer. Importantly, the CIP Rule permits flexibility with respect to the types of identifying information required in ways that facilitate financial inclusion. For example, if an individual does not have a residential or business street address, or an official Post Office box number, the residential or business street address of next of kin or of another contact individual, or a description of the customer's physical location, can be used, potentially accommodating homeless persons. Equally, where banks opt to use documentary methods to verify a customer's identity, the federal banking agencies’ expectation is that banks will review an unexpired form of identification issued by a government agency to the customer, evidencing nationality or residence and bearing photograph or similar safeguard, such as a driver’s license or passport. The CIP Rule neither endorses nor prohibits a bank from accepting particular types of government identification cards. The CIP Rule also permits use of non-documentary identification/verification methods, such as independently verifying identity through a third party, such as a credit reporting bureau (consumer credit report), public database or other source; an inquiry to a fraud detection system; and more traditional non-documentary methods, such as contacting a customer from the phone information provided, checking references with other financial institutions, and obtaining a financial statement.

(FATF and OECD, 2017, p. 14)

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