To assist the public, the banking industry and examiners, the staffs of the Board of Governors of the Federal Reserve System, Federal Deposit Insurance Corporation, Office of the Comptroller of the Currency, Office of Thrift Supervision, National Credit Union Administration, and the U.S. Department of the Treasury's Financial Crime Enforcement Network (collectively, the Agencies) have released an expanded frequently asked questions document (FAQs) to provide additional guidance on the customer identification program rules issued under section 326 of the USA PATRIOT Act.1 The expanded FAQs, which incorporate the FAQs previously released by the Agencies in 2004, are attached to this SR letter.
The expanded interpretive guidance addresses the applicability of the customer identification rules to data processing activities, to bank holding companies and their non-bank subsidiaries, and to subsidiaries of banks. The FAQs also provide additional guidance on the definitions of "account," "bank," and "customer."
Reserve Banks are asked to distribute this SR letter and the attached FAQs on customer identification programs to the domestic and foreign banking organizations supervised by the Federal Reserve as well as to supervisory and examination staff. If you have any questions regarding the FAQs or the Agencies' regulations issued under section 326, please contact Nina Nichols, Special Counsel (Manager), Enforcement Section, at (202) 452-2961, Bridget M. Neill, Manager, Anti-Money Laundering Policy and Compliance Section, at (202) 452-5235, or Bridget M. Spaniel, Senior Special Anti-Money Laundering Examiner, at (202) 728-5827.