Banking Undocumented Immigrants and Non-Citizens: Navigating BSA, CIP, CDD, FCRA, and Fair Lending

Serving non-resident alien customers can raise challenging questions about identification, documentation, tax reporting, account opening, lending, payments, and other compliance responsibilities.

This practical webinar will examine the requirements and risks financial institutions should consider throughout these customer relationships. Participants will explore how BSA/AML, customer identification and due diligence, OFAC, tax documentation, fair lending, lending, and deposit operations intersect, as well as where routine decisions can create unexpected compliance concerns.

Whether you are new to banking non-resident aliens or looking to strengthen existing practices, you’ll gain practical guidance for managing these relationships more consistently and confidently.

What You’ll Learn

• How non-resident aliens differ from other categories of foreign customers
• Key identification, documentation, and due diligence considerations
• Account-opening and servicing challenges
• BSA/AML, OFAC, and tax reporting implications
• Lending, underwriting, adverse action, and fair lending risks
• Common operational mistakes and practical ways to reduce risk

Topics Covered

• Understanding non-resident alien classifications
• Account opening and Customer Identification Program requirements
• Customer due diligence, red flags, and sanctions considerations
• Tax documentation, withholding, and reporting
• Lending and fair lending considerations
• Policies, procedures, exceptions, and operational controls
• Practical examples that demonstrate how requirements intersect

Who Should Attend

This webinar is designed for compliance and BSA/AML professionals, deposit and loan operations personnel, lenders and underwriters, branch and frontline staff, risk managers, auditors, quality assurance personnel, and anyone responsible for policies, procedures, monitoring, or training related to foreign customers.