‘Are You a US Citizen?’ and Other KYC Requirements Banks May Collect from Customers

Interview with The Washington Post

Josh Collins and his wife Jessica Salazar Collins were recently contacted by their bank to provide their citizenship status. The couple had been banking with Bank of America for almost two decades and decided to disregard the mailer. As a result, Bank of America temporarily froze the couple’s bank account. 

This story resonates with many around the country who have been locked out of their bank account — for weeks, according to The Washington Post.

In an interview with The Washington Post, Alma Angotti, managing director and co-lead of the global investigations and compliance practice at Guidehouse, discussed the requirements that banks need to collect about their customers. “There isn’t an explicit Treasury Department requirement for banks to ask about citizenship, but banks can decide what criteria they collect, including data that can help detect users who present risk of money laundering and terrorist financing.“

Banks are required to maintain accurate records of their customers, which comply with anti-money laundering, economic sanctions restrictions, and other programs administered by various government agencies. It may be helpful for a bank, for example, to collect information about a dual citizenship if the customer regularly remits money abroad.

Angotti stressed, however, that “banks and financial institutions need to figure out ‘what information do we need to really understand this customer.’” 

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