We are using a third party product to perform background and enhanced due diligence searches of higher-risk customers, including a search of local voter databases. We are not sure if we have a permissible purpose under Illinois law for accessing voter databases. In Missouri, we believe we can search voter databases for “use in connection with a permissible commercial purpose.” Does Illinois allow financial institutions to search voter databases for BSA purposes?

No, the Illinois Election Code generally prohibits “the disclosure of electronic voter registration records to any person or entity other than to a State or local political committee and other than to a governmental entity for a governmental purpose.”

Although individuals may be permitted to view the statewide voter registration list on a computer screen at the Springfield office of the State Board of Elections, the list may not be printed, duplicated or transmitted. Additionally, there are no circumstances under which such data may be used for business purposes, and persons who violate this prohibition are guilty of a Class 4 felony.

For resources related to our guidance, please see:

  • Illinois Election Code, 10 ILCS 5/4-8 (“To protect the privacy and confidentiality of voter registration information, the disclosure of electronic voter registration records to any person or entity other than to a State or local political committee and other than to a governmental entity for a governmental purpose is specifically prohibited except as follows: subject to security measures adopted by the State Board of Elections . . .  any person may view the centralized statewide voter registration list on a computer screen at the Springfield office of the State Board of Elections, during normal business hours other than during the 27 days before an election, but the person viewing the list under this exception may not print, duplicate, transmit, or alter the list. Copies of the tapes, discs, or other electronic data shall be furnished by the county clerk to local political committees and governmental entities at their request and at a reasonable cost. The individual representing a political committee requesting copies of such tapes shall make a sworn affidavit that the information shall be used only for bona fide political purposes, including by or for candidates for office or incumbent office holders. Such tapes, discs or other electronic data shall not be used under any circumstances by any political committee or individuals for purposes of commercial solicitation or other business purposes. . . . The prohibition in this Section against using the computer tapes or computer discs or other electronic data processing information containing voter registration information for purposes of commercial solicitation or other business purposes shall be prospective only from the effective date of this amended Act of 1979. Any person who violates this provision shall be guilty of a Class 4 felony.”)