Snapshot:
On September 8, 2026, FinCEN issued Frequently Asked Questions Regarding Treatment of Verifiable Digital Credentials Under the Customer Identification Program Rule, which clarified how banks and credit unions may use state-issued mobile driver’s licenses (mDLs) and other government-issued verifiable digital credentials (VDCs) when verifying customer identities under the Customer Identification Program (CIP) Rule. The guidance was issued jointly with the Federal Reserve, FDIC, NCUA, and OCC.
The agencies explained that an unexpired government-issued verifiable digital credential, such as a mobile driver’s license, may qualify as a government-issued identification document for CIP purposes if the institution maintains the technology necessary to extract and evaluate the credential’s information. The guidance also emphasizes that institutions must still satisfy all existing CIP requirements and evaluate indicators of fraud when relying on digital credentials. The agencies noted that the FAQs do not create new regulatory requirements or supervisory expectations.
Why it Matters:
As financial institutions continue expanding digital account opening capabilities, regulators are providing additional clarity on the use of modern identity-verification technologies. The guidance acknowledges that secure digital credentials can play a role in customer onboarding while reinforcing that institutions remain responsible for forming a reasonable belief that they know the true identity of their customers.
For compliance, BSA/AML, fraud, and digital banking teams, this update highlights the importance of understanding how emerging digital identity solutions fit within existing CIP frameworks. Institutions considering the use of mobile driver’s licenses or similar credentials should assess whether their onboarding systems, identity verification processes, and fraud controls appropriately support the use of these technologies while maintaining compliance with CIP requirements.