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ⓘ Address confidentiality program




                                     

ⓘ Address confidentiality program

An address confidentiality program allows victims of domestic violence, sexual assault, stalking or other types of crime to receive mail at a confidential address, while keeping their actual address undisclosed. This is usually done through the states Secretary of States address or some other address which will legally substitute the agencys address for the victims physical address on public records.

According to the National Network to End Domestic Violence,

Address Confidentiality Programs ACP and Confidential Voter Listings are programs administered by the state enabling victims of domestic violence and sometime victims of sexual assault and/or stalking to participate in the voting process without fear of being found by their abusers. ACPs generally provide a substitute address for all public records. Confidential Voter Listings only provide confidentiality on election-related public records.

                                     

1. Bank Accounts and Address Confidentiality

The rules implementing the Bank Secrecy Act require a financial institution to implement a Customer Identification Program that includes procedures that enable it to form a reasonable belief that it knows the true identity of its customers. The rules also require that a financial institution obtain a residential or business street address from each customer. Unfortunately, the substitute address under an Address Confidentiality Program does not meet the standards.

The Financial Crimes Enforcement Network issued a letter ruling to help the situation. The Financial Crimes Enforcement Network regulations also allow: "If the individual customer does not have a residential or business street address, then the rules permit the individual customer to provide a "residential or business street address of next of kin or of another contact individual."

In FIN-2009-R003, the Financial Crimes Enforcement Network found: "A customer who participates in a state-created ACP shall be treated as not having a residential or business street address and a secretary of state, or other state entity serving as a designated agent of the customer consistent with the terms of the ACP, will act as another contact individual for the purpose of complying with FinCENs rules. Therefore, a financial institution should collect the street address of the ACP sponsoring agency for purposes of meeting its CIP address requirement."

                                     
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