Verifying information Current

Verifying identity information actually came from a reliable source

Reliance has limits. Know when a document or form is genuinely sufficient, and when to check further.

Collecting a document or a signed form is only the first step. This guide sets out practical ways to check that identity or beneficial ownership information is genuinely reliable before you act on it. It is general information, not legal or tax advice.

Action plan

1 Check the identifying document image against the number stated in the record FinCEN's own instructions treat the document image as the evidence for the unique identifying number, not a formality.

For a beneficial owner's FinCEN filing, the required identifying document image needs to be complete, clear, and readable, and needs to show the page containing the unique identifying number and other identifying data. Before relying on a beneficial owner record, confirm the number recorded actually matches what appears on the submitted document image, rather than assuming the two match.

  • Compare the unique identifying number recorded against what actually appears on the document image
  • Confirm the image is complete, clear, and readable, not partial or illegible
  • Query a mismatch before treating the record as complete

Done when: The unique identifying number on file has been checked against the actual document image, not assumed correct

FinCEN: BOI report filing instructions
2 Rely on a properly completed Form W-9, but not past what you actually know A signed W-9 is generally sufficient, but a fact you already know overrides it.

The IRS's own instructions for requesters state that a properly completed and signed Form W-9 can generally be relied upon. That reliance has a limit: a requester may rely on a payee's claim unless they have actual knowledge that the information given is not valid. Where something you already know about the client contradicts what the form states, don't rely on the form's certification alone.

  • Treat a properly completed, signed Form W-9 as generally reliable
  • Don't rely on the form where you have actual knowledge that contradicts it
  • Document any known inconsistency and how it was resolved

Done when: A signed Form W-9 was relied on appropriately, with any actually-known inconsistency addressed rather than ignored

IRS: Instructions for the Requester of Form W-9
3 Cross-check a taxpayer identification number against IRS records before relying on it for reporting The IRS provides a free tool for exactly this check.

Before filing an information return, the IRS's TIN Matching Program lets an authorised payer check a payee-supplied name and taxpayer identification number combination against the IRS's own database through e-Services, with an interactive option for smaller volumes and a bulk option for larger ones.

  • Register for IRS e-Services before using the TIN Matching tool
  • Run a payee's name and TIN through TIN Matching before filing an information return that depends on it
  • Treat a non-match as a reason to follow up with the payee, not to file anyway

Done when: A payee's name and TIN combination has been checked through IRS TIN Matching before it was relied on for information-return filing

IRS: TIN matching tools
4 Escalate a genuine mismatch rather than accepting it at face value A document or form that doesn't check out needs a documented resolution, not a shrug.

Where a document image, a TIN match, or another check reveals a genuine inconsistency, escalate it through your firm's own client-verification process rather than proceeding on the strength of the original document or form alone.

  • Escalate an unresolved mismatch through your firm's own review process
  • Don't proceed with a matter on the basis of information you know to be unverified
  • Record what was checked, what didn't match, and how it was resolved

Done when: A genuine mismatch was escalated and documented rather than accepted without resolution

See storing client identity evidence securely