BSA & Customer Identification Program Explained - Anonymousllc.co's 2026 reference. Covers the rule, the controlling statute or regulation, common questions, and how Anonymousllc.co handles it in practice. Primary-source citations linked throughout.
The Bank Secrecy Act (BSA) is the US anti-money-laundering law that requires banks to verify who they do business with, and the Customer Identification Program (CIP) is the specific rule - 31 CFR 1020.220 - that forces a bank to identify every account holder before opening an account. Together they explain why a bank knows your identity even when your LLC is anonymous on state records. The CIP rule flows from Section 326 of the USA PATRIOT Act, which amended the BSA. Every US bank, credit union, and regulated fintech partner applies it. There is no anonymous bank account for a US LLC, and no formation service can change that. This distinction is the single most important thing to understand about anonymous LLCs: anonymity is a public-records concept, not a banking one. Coverage is current as of the "Last updated" date at the top of the page.
The Bank Secrecy Act, codified at 31 USC § 5311 and following, is the 1970 law that requires financial institutions to keep records and file reports that help detect money laundering. It is the statutory foundation for CIP, beneficial-ownership rules, and Suspicious Activity Reports. The USA PATRIOT Act of 2001 expanded the BSA with new customer-identity requirements. Section 326 directed the Treasury and FinCEN to write the CIP rule that banks follow today. That rule is what turns the statute into a concrete checklist at account opening. The BSA framework is enforced by FinCEN and the federal banking regulators. Penalties for a bank that skips identity verification are severe, which is why banks apply CIP to every LLC account without exception.
Under 31 CFR 1020.220, a bank must collect a customer's name, date of birth, address, and an identifying number before opening an account, then verify that identity using documents or non-documentary methods. For a business account, the bank identifies both the entity and the people who control it. The rule sets a minimum: name, address, and taxpayer identification number for the entity, plus identity verification for the beneficial owners and the person opening the account. Banks add their own risk-based checks on top of this floor. For an LLC, the taxpayer identification number is the EIN. That is why the EIN is a prerequisite to banking, and why Anonymousllc.co delivers it before the account application goes out.
The bank knows your identity because CIP requires it, and CIP applies regardless of state anonymity. State filings in Wyoming, New Mexico, Delaware, and Nevada omit members and managers from public records, but the bank operates under federal law that demands identity verification. Think of two separate ledgers. The public state ledger shows only the LLC name and registered agent. The bank's private ledger, held under BSA/CIP rules, shows the beneficial owner's full identity. The public ledger is what anonymity protects; the private ledger is confidential to the bank, not public. This is not a loophole or a weakness. It is the design. Anonymity keeps your name off search-engine-indexed public records; it was never meant to hide you from a regulated bank.
A bank collects the LLC's EIN, the Articles of Organization, the operating agreement, and identity documents for the beneficial owner. This is the standard CIP package for a business account, and having all four ready is what separates a smooth approval from a stalled application. The EIN confirms the entity's taxpayer identity. The Articles prove the entity legally exists. The operating agreement shows who owns and controls the LLC. The owner's passport or government ID satisfies personal identity verification. Anonymousllc.co delivers the EIN, Articles, and operating agreement at formation, so the CIP checklist is complete before you apply to Mercury, Relay, or Bluevine. The only item you supply is your own identity document.
Alongside CIP, FinCEN's Customer Due Diligence rule requires banks to identify beneficial owners who hold 25% or more of an entity and the individual who controls it. For a single-member LLC, that is one person: you. The bank records that person's identity as part of onboarding. This rule is separate from the FinCEN BOI reporting obligation. Banks collect beneficial-ownership information for their own files; they do not send it to a public register. The data stays inside the bank's compliance records. A multi-member LLC lists each owner at or above the 25% threshold plus one control person. Anonymousllc.co structures the operating agreement so ownership percentages are clear, which keeps the bank's beneficial-ownership review straightforward.
US banks run the same CIP verification for non-resident owners, which is why non-resident banking involves extra know-your-customer review. The bank still needs the EIN, the formation documents, and a verified identity - a passport for a non-resident who has no SSN. A non-resident without a Social Security Number is verified through the passport and, where required, an ITIN. Anonymousllc.co obtains the EIN by fax for non-residents in 4-6 weeks and provides the ITIN for $299 when a bank or tax matter calls for one. Because the CIP standard does not bend for non-residents, we apply to 4-5 partner banks that accept non-resident-owned US LLCs. Applying in parallel raises the odds of a fast approval and keeps the 90% approval rate intact.
Banking runs 8-10 days after the EIN issues, once CIP verification and account review complete. The EIN is the gating item, so the banking clock starts when the IRS assigns the number, not when the LLC is filed. For US residents, the EIN issues in 5-7 days and the account follows within roughly 8-10 days. For non-residents, the EIN takes 4-6 weeks by fax, after which the same 8-10 day banking window applies. Anonymousllc.co submits applications to 4-5 partner banks - Mercury, Relay, and Bluevine among them - and the approximate approval rate across the pool is 90%. Applying to several banks at once absorbs the variability in any single bank's KYC queue.
Anonymity keeps your name out of public state records, court exhibits, and the data brokers that scrape them - it does not hide you from a regulated bank or the IRS. The protection is real, but it is bounded by the BSA/CIP framework. Your identity sits in three private places: the operating agreement, the bank's BSA/CIP file, and the IRS EIN record. None of these is a public register, and none is searchable by a competitor, a litigant scanning filings, or a marketing list. What anonymity stops is the routine exposure that comes from a member's name appearing on a state's public entity search. In Wyoming, New Mexico, Delaware, and Nevada, that name simply is not there.
Anonymousllc.co assembles the full CIP package at formation - EIN, Articles of Organization, and operating agreement - then applies to 4-5 partner banks so the identity documents you supply move straight into onboarding. The Anonymous LLC formation is $397 all-in. We set the operating agreement so ownership percentages and the control person are unambiguous, which is what a bank's beneficial-ownership review checks. For non-residents, we add the EIN-by-fax track and the $299 ITIN where a bank requires it. Start the intake on WhatsApp. We confirm scope, deliver the formation documents, and submit the bank applications so the CIP checklist is satisfied on the first pass.
Government, regulator, and primary-source documents underpinning this page.
5-minute WhatsApp intake. 5-10 day turnaround.