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Financial Institutions › Data Collection › Bank Secrecy Act

Bradley Arant Boult Cummings LLP

A New Rule Embraces Modernity in the Customer Identification Process

Bradley Arant Boult Cummings LLP on

Financial institutions across the United States have grappled with compliance requirements under the Customer Identification Program (CIP) Rule for more than two decades. A new exemption, approved in June 2025, promises...more

Morrison & Foerster LLP

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

Morrison & Foerster LLP on

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

Foodman CPAs & Advisors

Is the “FinCEN Query” a Gateway to Convergence?

Foodman CPAs & Advisors on

FinCEN’s (a bureau of the U.S. Department of the Treasury) primary purpose is  protecting the financial system from illicit use, combating money laundering, and promoting national security through the collection, analysis,...more

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