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OCC Bulletin 2026-44 | September 8, 2026

Bank Secrecy Act/Anti-Money Laundering: Frequently Asked Questions Regarding Treatment of Verifiable Digital Credentials Under the Customer Identification Program Rule

To

Chief Executive Officers of All National Banks, Federal Savings Associations, and Federal Branches and Agencies; Department and Division Heads; All Examining Personnel; and Other Interested Parties

Summary

On September 8, 2026, the Office of the Comptroller of the Currency (OCC), jointly with the Financial Crimes Enforcement Network (FinCEN), the Board of Governors of the Federal Reserve System, the Federal Deposit Insurance Corporation, and the National Credit Union Administration, issued answers to frequently asked questions (FAQ) related to the use of state-issued mobile driver’s licenses and other government-issued verifiable digital credentials (VDC). The answers to these FAQs clarify how banks may use such VDCs to comply with the Customer Information Program (CIP) Rule.1

Note for Community Banks

This bulletin is applicable to all community banks.2

Highlights

These FAQs address the following topics:

  • The definition of a VDC.
  • The application of the CIP Rule to banks’ use of VDCs.
  • The amendment of previously issued FAQs that update terminology used to describe VDCs.

Further Information

Please contact the Compliance and Operational Risk Division, Office of the Chief National Bank Examiner, at (202) 649-6550.

 

James M. Gallagher
Senior Deputy Comptroller and Chief National Bank Examiner

Related Link

1 31 CFR 1020.220.

2 “Banks” refers collectively to national banks, federal savings associations, and federal branches and agencies of foreign banking organizations. OCC News Release 2025-89 (September 18, 2025) identifies “community banks” as institutions with up to $30 billion in assets.

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