Online and Not In-Person Checklist for Compliance Concerns
Updated 03/04/2026
This tool covers requirements and best practices for online and non-in-person account opening.
Rule: 31 CFR Part 1020 Subpart B, 31 CFR Part 1010 Subpart B, FFIEC BSA/AML Examination Manual
Toolkit: Mobile Banking, New Accounts – Consumer, New Accounts Commercial
Keywords: BSA, AML/CFT, Beneficial Ownership, CIP, Verification of information, Disclosures, Privacy concerns, PATRIOT Act
3/2/2026 – Updated to add note referencing FinCEN Exceptive Relief (FIN-2026-R001), issued February 13, 2026.
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