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March 11, 2014: FinCEN grants exception to forms of identity for FX dealers

File this under CIP (Customer Identification Program) – until this ruling, non-resident aliens had to provide a valid passport as proof of identity. Now, certain US documents are also acceptable:

Since the issuance of the original recordkeeping and verification requirements for dealers in
foreign exchange, the United States has authorized non-resident aliens under certain
circumstances to verify their identities and admissibility into the United States with documents
other than passports when crossing the border. As a result, non-resident aliens seeking to
exchange currency may not be holding a passport issued by their country of origin. Under these
circumstances, a dealer in foreign exchange may be unable to comply with the requirement to
record a customer’s passport number in connection with verifying the identity of a non-resident
alien. These non-resident aliens would, however, have a document issued by a U.S. Federal or
state agency allowing their legitimate entry into the United States.

The amended regulation now reads:

Each dealer in foreign exchange shall retain either the original or a microfilm or
other copy or reproduction of each record of each exchange of currency involving
transactions in excess of $1,000, including the name and address of the customer,
date and amount of the transaction, and currency name, country, and total amount
of each foreign currency. Unless the transaction is received by mail or common
carrier, each dealer in foreign exchange shall also retain the customer’s taxpayer
identification number and the number and description of the government
document used to verify the customer’s identity (or, if the customer is a non-
resident alien, the number of the passport issued by the country of origin or the
number and description of an alternate valid entry document issued by a U.S.
Federal or state government agency).


FinCEN Ruling


Categories: FinCEN Updates Guidance


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