Yes, we believe that FinCEN’s customer identification program (CIP) requirements would allow your bank to rely on an Illinois FOID card to verify a customer’s identity, although whether you choose to accept this card for CIP purposes remains a business decision for your bank.

When verifying a new individual customer, banks must obtain the person’s name, birthdate, address and taxpayer identification number based on documents that include certain characteristics. FinCEN’s rules state that an acceptable document would include an “unexpired government-issued identification evidencing nationality or residence and bearing a photograph or similar safeguard, such as a driver’s license or passport.” Interagency guidance on CIP procedures further clarifies that “other forms of identification may be used if they enable the bank to form a reasonable belief that it knows the true identity of the customer.”

Illinois FOID cards are issued by the State of Illinois through the Illinois State Police, and they include an individual’s photograph, birthdate and address, among other items of information. Consequently, we believe these cards may be relied on for CIP purposes. At the same time, your bank continues to have the discretion to make a risk-based decision as to whether to rely on an Illinois FOID card to verify a new customer’s identity on a case-by-case basis. 

For resources related to our guidance, please see:

• FinCEN Regulations, 31 CFR 1020.220(a)(2)(i) (“[T]he bank must obtain, at a minimum, the following information from the customer prior to opening an account: (1) Name; (2) Date of birth, for an individual; (3) Address, . . . and (4) Identification number, which shall be: For a U.S. person, a taxpayer identification number; . . .”)

• FinCEN Regulations, 31 CFR 1020.220(a)(2)(ii)(A) (“Verification through documents. For a bank relying on documents, the CIP must contain procedures that set forth the documents that the bank will use. These documents may include: (1) For an individual, unexpired government-issued identification evidencing nationality or residence and bearing a photograph or similar safeguard, such as a driver’s license or passport . . . .”)

• Interagency FAQs: Final CIP Rule (“Q: Can a bank use an employee identification card as the sole means to verify a customer’s identity? A: A bank using documentary methods to verify a customer’s identity must have procedures that set forth the documents that the bank will use. The CIP rule gives examples of types of documents that have long been considered primary sources of identification and reflects the Agencies’ expectation that banks will obtain government-issued identification from most customers. However, other forms of identification may be used if they enable the bank to form a reasonable belief that it knows the true identity of the customer. Nonetheless, given the availability of counterfeit and fraudulently obtained documents, a bank is encouraged to obtain more than a single document to ensure that it has a reasonable belief that it knows the customer’s true identity.”)

• Firearm Owners Identification Card Act, 430 ILCS 65/6(a) (“A Firearm Owner's Identification Card, issued by the Department of State Police at such places as the Director of the Department shall specify, shall contain the applicant's name, residence, date of birth, sex, physical description, recent photograph, except as provided in subsection (c-5), and signature.”)