Regulatory Alerts2026-09-08
Added
Frequently Asked Questions Regarding Treatment of Verifiable Digital Credentials Under the Customer Identification Program Rule
New frequently asked questions (FAQs) and an amendment to a previously issued FAQ clarify that banks and credit unions may use government-issued verifiable digital credentials (VDCs), including state-issued mobile driver’s licenses (mDLs), to verify natural person customer identities under the Customer Identification Program (CIP) Rule. These clarifications, issued by the Financial Crimes Enforcement Network (FinCEN) and several Agencies, state that an unexpired, government-issued VDC qualifies as "government-issued identification" if it evidences nationality or residence and bears a photograph or similar safeguard, and the institution has the necessary technology and its CIP permits such use. For VDCs issued by non-government third parties, banks and credit unions must ensure the third party employs the same authentication level as the institution itself. Importantly, these FAQs do not alter existing Bank Secrecy Act legal or regulatory requirements or establish new supervisory expectations.