To provide banks with more flexibility in meeting compliance requirements, the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) has issued an order allowing banks to collect Tax Identification Number (TIN) information from third parties instead of directly from customers. This decision considers public feedback received following an interagency request for information.
"We recognize that the way customers interact with banks and receive financial services has changed significantly since 2001, when the initial requirement was enacted into law under the USA PATRIOT Act," said FinCEN Director Andrea Gacki. "This order reduces burden by providing banks with greater flexibility in determining how to fulfill their existing regulatory obligations without presenting a heightened risk of money laundering, terrorist financing, or other illicit finance activity."
The order was issued in coordination with the Office of the Comptroller of the Currency, the Federal Deposit Insurance Corporation, and the National Credit Union Administration. It allows banks under these agencies' jurisdiction to use alternative methods for obtaining TIN information as long as they comply with the Customer Identification Program (CIP) Rule.
The CIP Rule mandates written procedures enabling banks to obtain TIN information before opening an account based on risk assessments. These procedures must be risk-based for verifying customer identities reasonably and practicably.
Banks are not required to adopt this alternative method; its use is optional. In March 2024, FinCEN and related agencies requested public input on potential risks and benefits if banks were allowed to source TIN information from third parties before account openings. The exemption granted reflects comments received and advances in identity verification tools available to financial institutions.
Further details can be found in the official order at: https://www.fincen.gov/sites/default/files/2025-06/CIP-TIN-Exemption-Order-final508.pdf
