No, you are not required to obtain a sole proprietorship resolution to open a sole proprietorship account.

When documenting a new sole proprietorship account, you should follow your Customer Identification Program (CIP) procedures. FinCEN’s CIP Rule guidance provides that when opening a sole proprietorship account, you may use the sole proprietorship’s fictitious or assumed name certificate to verify its identity. In the absence of such documentation, you should obtain the sole proprietor’s name, address, date of birth and tax identification number to verify the sole proprietor’s identity.

For resources related to our guidance, please see:

• FRB BSA Regulations, 12 CFR 208.63(b)(2) (“Each bank is subject to the requirements of 31 U.S.C. 5318(l) and the implementing regulation jointly promulgated by the Board and the Department of the Treasury at 31 CFR 103.121, which require a customer identification program to be implemented as part of the BSA compliance program required under this section.”)

• FinCEN Regulations, 31 CFR 1020.220(a)(2) (“The CIP must include risk-based procedures for verifying the identity of each customer to the extent reasonable and practicable. The procedures must enable the bank to form a reasonable belief that it knows the true identity of each customer. These procedures must be based on the bank’s assessment of the relevant risks, including those presented by the various types of accounts maintained by the bank, the various methods of opening accounts provided by the bank, the various types of identifying information available, and the bank's size, location, and customer base. At a minimum, these procedures must contain the elements described in this paragraph (a)(2).”)

• FinCEN CIP Rule FAQs (“5. How should a bank verify the identity of a sole proprietorship that opens a new account, (such as an account titled in the name of an individual ‘doing business as’ a sole proprietorship) when there are no documents or non-documentary methods that will establish the identity of the sole proprietorship? In some states, sole proprietorships are required to file ‘fictitious’ or ‘assumed name certificates.’ Banks may choose to use these certificates as a means to verify the identity of a sole proprietorship, if appropriate. However, when there are no documents or non-documentary methods that will establish the identity of the sole proprietorship, the bank must undertake additional verification by obtaining information about the sole proprietor or any other individual with authority or control over the sole proprietorship account — such as the name, address, date of birth, and taxpayer identification number of the sole proprietor, or any other individual with authority or control over the account — in order to verify the sole proprietorship’s identity, as described in 31 C.F.R. § 103.121(b)(2)(ii)(C).”)

• 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; . . .”)