In April, I predicted that an executive order then under discussion on bank reporting and citizenship would be more tedious than burdensome for its targets. Now that Executive Order 14406 and guidance from the Financial Crimes Enforcement Network and the Consumer Financial Protection Bureau are out, I can say I was half right.
Instead of requiring proof of citizenship—which Treasury Secretary Scott Bessent endorsed—the guidance focuses on individual taxpayer identification numbers, used by human taxpayers who don’t have Social Security numbers, as a potential risk factor banks need to assess.
The FinCEN advisory shouldn’t be a significant burden ...
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