What's New? FinCEN Updated FAQ on Verifiable Digital Credentials

On September 8, 2026, FinCEN and federal financial regulators issued joint guidance clarifying how banks and credit unions may accept state-issued mobile driver's licenses (mDLs) and other verifiable digital credentials (VDCs) under the Customer Identification Program (CIP) Rule. Under the updated FAQs, unexpired government-issued VDCs qualify as acceptable documentary identification if they evidence nationality or residence, include a photograph or comparable safeguard, and the institution possesses systems to extract the credential data. For non-government third-party digital credentials used in non-documentary verification, banks remain responsible for confirming that the issuing entity's authentication standards match their own. Although the guidance does not alter Bank Secrecy Act requirements, institutions planning to accept digital IDs should ensure their CIP policies explicitly permit them, confirm technology readiness, and update onboarding workflows to detect potential fraud.

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