FinCEN issues New FAQs Permitting the Use of Mobile Driver's Licenses and Digital Credentials Under CIP Rule

FinCEN, together with the Federal Reserve, FDIC, NCUA, and OCC, issued two new FAQs (plus an amendment to a prior CIP FAQ) confirming that banks and credit unions may rely on unexpired, government-issued verifiable digital credentials (VDCs)—including state-issued mobile driver's licenses—as documentary identity verification, provided the credential evidences nationality or residence, bears a photograph or similar safeguard, and the institution can technically extract and validate the underlying data. The amended FAQ separately clarifies that non-government-issued electronic credentials or VDCs may also serve as a non-documentary verification method, so long as the issuing third party applies an authentication standard equivalent to the institution's own.