To our clients and friends:
On June 27, 2025, the FDIC, the OCC, and the NCUA issued an order (the “Order”) exempting their supervised institutions from the Customer Identification Program Rule’s requirement to obtain taxpayer identification numbers directly from customers at account opening, permitting them to instead obtain this information from a third-party source. The Order is a significant step forward in modernizing the Bank Secrecy Act and FinCEN’s anti-money laundering regulations. Our Alert covering the Order and key takeaways is available here.
Luse Gorman regularly advises financial institutions regarding compliance with the Bank Secrecy Act, USA PATRIOT Act, Anti-Money Laundering Act of 2020, and FinCEN’s anti-money laundering regulations. If you have any questions about this Alert, please contact the authors. To learn more about our firm and services, please visit our website.