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Speakers raise access and regulatory concerns over banking verification for Puerto Rico

5717609 · September 4, 2025

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Summary

Participants discussed how proposed customer-identification and anti-money-laundering verification measures could affect banking access in Puerto Rico, citing federal statutes and agencies and flagging potential barriers for elderly and cognitively impaired customers; no formal vote was recorded.

Participants at the meeting discussed proposed customer-identification and anti-money-laundering (AML) measures and how they could affect banking access for Puerto Rico residents, with speakers raising concerns about verification methods, federal compliance and potential impacts on elderly and cognitively impaired customers.

Speakers said the discussion touched on specific federal requirements and agencies, including Customer Identification Program (CIP) rules, Customer Due Diligence (CDD) and Enhanced Due Diligence, the Bank Secrecy Act of 1970, the International Money Laundering Abatement and Financial Anti-Terrorism Act of 2001, the Money Laundering Control Act of 1986, the Financial Crimes Enforcement Network (FinCEN) and the Consumer Financial Protection Bureau (CFPB). Speaker C summarized the regulatory point by saying, “Know your customer.”

The conversation emphasized practical access issues. Several speakers described scenarios in which family-based recognition or electronic-only verification could exclude people with limited digital access or cognitive limitations. One speaker described the need for tactile or doorstep banking services and family-recognition processes to ensure older adults and people with cognitive impairment can complete transfers or receive benefited payments. The transcript includes discussion of “doorstep Banking services,” “tactile automatic” interfaces and concerns that purely electronic methods could leave some Puerto Rico residents without workable options.

Speakers also discussed how Puerto Rico would be treated within the federal banking and deposit-insurance systems. The transcript records repeated references to including Puerto Rico as part of the dual system and to the Depository Insurance Corporation. Participants flagged that federal requirements — including enhanced due diligence tied to AML statutes — could impose implementation burdens on local banks and cooperatives, and one speaker noted a related governor-level policy priority to reduce what they called “over regulation.”

On program design and procurement, Speaker C said the meeting record shows the project “does not contemplate” a vendor manager role for implementation. Participants noted gaps in the project description and asked for clarity on which entities would perform identity verification and how household or family recognition would be handled in electronic transfers.

No formal motions or votes are recorded in the transcript excerpts provided. The discussion combined legal and technical concerns — federal law compliance, bank-level operational capacity and accessibility for vulnerable groups — and speakers repeatedly requested clearer implementation details before any definitive policy action.

The meeting concluded with speakers urging further clarification from staff or proposers on how verification procedures would be executed in practice, how Puerto Rico would be integrated into federal systems, and what safeguards would be adopted to avoid excluding elderly or cognitively impaired customers.