US
TransitionSource check: 18 July 2026

United States KYC requirements

A bank’s written Customer Identification Program must collect four core identity fields and use risk-based documentary or non-documentary procedures that give it a reasonable belief it knows the customer’s true identity.

Primary lawBank Secrecy Act customer identification rules
Lead sourceFinCEN and federal functional regulators
Baseline retention5 years

01 / Scope

Who United States KYC rules cover

There is no single U.S. KYC rule for every business. This summary covers banks subject to 31 CFR 1020.220. Broker-dealers, mutual funds, futures firms, MSBs, and other sectors use separate BSA rules.

02 / Start the check

When United States customer due diligence starts

  • Before opening a new account, collect the minimum identifying information, subject to the rule’s limited treatment for customers applying for a taxpayer identification number.
  • Verify identity within a reasonable time after the account is opened using procedures appropriate to the bank’s products, customers, and risk profile.
  • Resolve circumstances where identity cannot be verified and define when not to open, when to close, and when to file a suspicious activity report.

03 / Evidence

Identity data required for United States KYC

  • Name.
  • Date of birth for an individual.
  • Residential or business street address, with limited alternatives stated in the rule.
  • Identification number: generally a U.S. taxpayer identification number, or specified passport or other government-document information for a non-U.S. person.

Verification methods and evidence

  • Documentary procedures may use an unexpired government-issued ID showing nationality or residence and bearing a photograph or similar safeguard for an individual.
  • Non-documentary procedures may include contacting the customer, comparing information with a consumer reporting agency, public database, or other source, checking references, or obtaining a financial statement.
  • The program must address non-face-to-face openings, unfamiliar or unavailable documents, and other circumstances with elevated identity risk.

04 / Entity customers

Beneficial-owner and representative checks

The separate CDD Rule at 31 CFR 1010.230 addresses covered legal-entity customers. FinCEN order FIN-2026-R001 now permits covered financial institutions to identify and verify beneficial owners at the first account, when prior information becomes doubtful, and when risk-based ongoing CDD calls for it, rather than at every additional account opening.

05 / After onboarding

Ongoing KYC monitoring in United States

The bank’s broader AML program and CDD obligations require customer-risk understanding and risk-based ongoing monitoring. CIP is the account-opening identity layer, not the full program.

Record retention

Keep core identifying information for five years after the account closes. Keep the description and results of verification, and discrepancy-resolution records, for five years after the record is made.

06 / Build notes

How to implement United States KYC requirements

  1. Route by regulated entity and account definition before choosing a verification flow.
  2. Store which documentary and non-documentary procedures were used and the discrepancy outcome.
  3. Keep sanctions screening, legal-entity CDD, and ongoing monitoring as connected but distinct controls.
  4. Define explicit outcomes for cannot verify: reject, restrict, close, escalate, and consider SAR.

07 / Related answers

Questions behind international KYC implementation

08 / Source ledger

Primary sources for United States KYC rules

We use regulator and legislation publishers here, not vendor explainers. Pinpoint citations show where to begin; the linked instrument controls.

01
Customer Identification Program requirements for banks

31 CFR 1020.220 Minimum data, verification procedures, records, and customer notice.

02
Customer Due Diligence requirements

31 CFR 1010.230 Separate requirements for covered legal-entity customers.

03
FinCEN CDD Rule resource page

CDD Rule Regulator materials and FAQs for customer due diligence.

04
FinCEN exceptive relief FIN-2026-R001

issued 13 February 2026 Current relief from repeating beneficial-owner identification and verification at every new account for an existing legal-entity customer.

05
Official annual CFR edition

31 CFR 1020.220 GovInfo source for the bank CIP provision.

Source review completed 18 July 2026. This page is a structured research summary, not a legal opinion or a substitute for sector-specific advice.