Thursday, February 15, 2024

Starting Up - Banking Identity... (pt 2)

 I remember someone telling me once that the government, or congress, writes legislation. But that document has to be turned into rules and regs by the various agencies and groups that deal with the policy. Turns out, that is true for this question as well.

The last item for identification is "other relevant information," which is broad and vague to allow for breadth. It turns out that the site for the BSA/AML manual to direct examinations 

https://bsaaml.ffiec.gov/manual

both goes into more details and send the reader to The Code of Federal Regulations

https://www.ecfr.gov/current/title-31/subtitle-B/chapter-X/part-1020#1020.220

It turns out that there really isn't a more detailed requirement beyond the Big 4...

1. Name 

2. Address

3. Date of Birth

4. Identification Number (e.g. SS#)

But you can imagine that a bank would want to get information beyond this for anyone working or making their money from something less than up the middle of Broadway (e.g. pawn shop).

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