Compliance PracticeFinTech & RegTechNorth AmericaRegulation & Policy

US Regulators Clarify Use of Mobile Digital IDs for Customer Identification

U.S. financial regulators have clarified how banks and other covered financial institutions may use mobile driver’s licences and other verifiable digital credentials when verifying the identity of natural-person customers under the Customer Identification Program (CIP) Rule.

On 8 September 2026, FinCEN, together with staff from the Federal Reserve, FDIC, NCUA and OCC, issued two new FAQs and updated an existing FAQ addressing government-issued verifiable digital credentials.

The agencies confirmed that an unexpired government-issued digital credential may qualify as documentary verification where it evidences nationality or residence and includes a photograph or similar safeguard. The institution must have technology capable of receiving and validating the credential and must allow the method within its own CIP procedures.

The guidance also explains that non-government digital credentials may be used as a non-documentary verification method where permitted by the institution’s CIP. Institutions remain responsible for using appropriate authentication controls and for forming a reasonable belief that they know the true identity of the customer.

The FAQs do not amend the Bank Secrecy Act or create new supervisory expectations. Instead, they clarify how existing CIP requirements apply as government-issued digital identity systems become more widely available.

For compliance teams, the update provides useful regulatory certainty for digital onboarding while reinforcing that technology adoption must remain embedded within documented CIP controls.

Sources

Financial Crimes Enforcement Network, “FinCEN Issues Frequently Asked Questions Regarding Treatment of Verifiable Digital Credentials Under the Customer Identification Program Rule”, 8 September 2026.

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