Which of the following is NOT considered an acceptable form of identification for an individual when completing a CTR?

When completing a CTR, a bank must verify the identity of the individual conducting the transaction by examining a document. Acceptable documents are typically government-issued and contain a photograph, name, and address. A "long-term deposit account relationship" is not a physical document and is therefore not an acceptable form of identification for this purpose, even if it is part of the bank's overall Customer Identification Program (CIP). The bank must rely on a specific, qualifying identification document.

A. A U.S. passport is a government-issued photo identification document and is explicitly listed as an acceptable form of ID.
C. A state-issued driver's license is a primary and acceptable form of government-issued photo identification.
D. A photo identification card issued by a government agency (state, local, or federal) is an acceptable form of identification.

1. Financial Crimes Enforcement Network (FinCEN). (2023). FinCEN Form 104, Currency Transaction Report Electronic Filing Instructions. "Item 15, ID Information," Page 11. The instructions specify verifying identity by examining a document, listing examples such as a Driver's License, Military ID, and Passport. A relationship is not listed as a document.

2. Federal Financial Institutions Examination Council (FFIEC). (2021). Bank Secrecy Act/Anti-Money Laundering Examination Manual. "Currency Transaction Reporting – Identification Requirements," Page 136. "For each currency transaction of more than $10,000, a bank must verify and record the identity of the individual presenting the transaction(s)..." The section emphasizes the examination of documents.