On June 27, 2025, FinCEN issued an order permitting banks to collect Tax Identification Number (TIN) information from a third party rather than from the bank’s customer. FinCEN said that this action is aimed at providing banks with greater flexibility in fulfilling compliance obligation without presenting a heightened risk of money laundering, terrorist financing, or other illicit finance activity.

The FinCEN order takes into account public comments received in response to an interagency request for information issued in 2024 that sought public input on the potential risks and benefits, as well as safeguards that could be established, if banks were permitted to obtain part or all of a customer’s TIN information from a third-party source prior to opening an account rather than from the customer. FinCEN and the Agencies considered comments received in granting this exemption from one aspect of the CIP TIN collection requirements.

Read FinCEN’s press release here.

The order can be found here.

Adam Witmer

Adam Witmer is a speaker, author, and founder of the Compliance Cohort. Adam has taught hundreds of seminars and training sessions to thousands of bankers throughout the United States and teaches on all areas of regulatory compliance. Adam has written five e-books that he never published, hit a grizzly bear while driving in a National Park, and is an award winning photographer and musician (though he no longer takes photos nor plays any instruments). In his spare time, Adam can be found kayaking on the lake, doing taekwondo with his kids, working on his (project) house, or spending time with his family.

Website

Become a Free Member