No, a foreign ID by itself is not enough; your qualifying foreign passport or photo ID can identify you, but a U.S.-formed business account also needs company information and a taxpayer number.

(a)(2)(i)(A)(4)(ii)

For a non-U.S. person, one or more of the following: A taxpayer identification number; passport number and country of issuance; alien identification card number; or number and country of issuance of any other government-issued document evidencing nationality or residence and bearing a photograph or similar safeguard.

(a)(2)(i)(A)(3)(i)

For an individual, a residential or business street address;

(a)(2)(i)(A)(4)(i)

For a U.S. person, a taxpayer identification number;

Definition of U.S. person

A person other than an individual (such as a corporation, partnership or trust), that is established or organized under the laws of a State or the United States.

(a)(2)(ii)(A)(2)

For a person other than an individual (such as a corporation, partnership, or trust), documents showing the existence of the entity, such as certified articles of incorporation, a government-issued business license, a partnership agreement, or trust instrument.

(a)(2)(i)(B)

Instead of obtaining a taxpayer identification number from a customer prior to opening the account, the CIP may include procedures for opening an account for a customer that has applied for, but has not received, a taxpayer identification number.

Get an EIN: Form your entity first

Form your entity first: If you’re creating a legal entity (LLC, partnership, corporation), register it with your state before you apply for an EIN.

Get an EIN

You can get an EIN for free directly from the IRS in minutes.

Lines 7a–7b

Enter “foreign” or N/A on line 7b if the responsible party doesn’t have and is ineligible to obtain an SSN or ITIN.

How To Apply for an EIN: Apply online

The principal officer, general partner, grantor, owner, trustor, etc., must have a valid taxpayer identification number (SSN, EIN, or ITIN) in order to use the online application.

B.7

As with CIP for individual customers, covered financial institutions must collect from the legal entity customer the name, date of birth, address, and social security number or other government identification number (passport number or other similar information in the case of foreign persons) for individuals who own 25% or more of the equity interest of the legal entity (if any), and an individual with significant responsibility to control/manage the legal entity.

Order

A covered financial institution may instead limit its identification and verification of the identities of beneficial owners under 31 C.F.R. § 1010.230 to the following scenarios: (1) when a legal entity customer first opens an account with a covered financial institution, (2) any time thereafter when the covered financial institution has knowledge of facts that would reasonably call into question the reliability of beneficial ownership information previously obtained about the legal entity customer, and (3) as needed based on a covered financial institution’s risk-based procedures for conducting ongoing customer due diligence.

Question 22

Sole proprietorships—individual or spousal—and unincorporated associations are not legal entity customers as defined by the Rule.

Some financial institutions accept foreign passports and consular identification documents.

(e)(12)

Capital in the process of being invested or that has been invested must be irrevocably committed to the enterprise.