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FOS Blog

12 Feb

Did You Know It’s Illegal to Photocopy a Military ID

Did You Know It’s Illegal to Photocopy Military ID;
How to Comply with CIP Requirements?

Many institutions include military identification cards as a primary form of identification for meeting the Bank Secrecy Act (BSA) standards for a Customer Identification Program (CIP). FinCEN Chapter X Section 1020.220(a)(2)(ii)(a)(1) related to verification through documentation states “the CIP must contain procedures that set forth the documents that the bank will use. These documents may include (1) For an individual, unexpired government-issued identification evidencing nationality or residence and bearing a photograph or similar safeguard, such as a driver’s license or passport”.

Historically, institutions have recognized military identification to fit this description and have incorporated it into their BSA/CIP programs. However, did you know that it is illegal to photocopy military identification? 18 USC, Part I, Chapter 33, Section 701 defines this prohibition. Photocopying military identification can subject a person to fines and imprisonment up to 6 months. If your BSA/CIP program calls for the photocopying of identification and you include military identification in permissible identification, you may want to revamp your CIP requirements. It is permissible to record the information from the military identification (name, address, date of birth, and taxpayer identification number), but it’s simply not permissible to photocopy it.

For more information on the prohibition, visit or contact one of our compliance professionals.

For additional information please contact the author Evelyn Dehmey at