The selfie, the bill and the Social Security number
Take exchange Kraken. Its document requirements page, last updated October 28, 2026, asks for a passport, driver’s license or national identity card, and for a proof of address no more than three months old. US clients add a Social Security number or an ITIN, and anyone living in the US or South Africa also sends a face photo.
Is all of that the law? Partly. The table maps each item to the clearest list in US rules.
| Item | Rule behind it |
|---|---|
| Name, date of birth, street address | Required before a bank account opens, under 31 CFR 1020.220 |
| SSN or ITIN | The same rule’s taxpayer number for a US person |
| Passport, driver’s license or ID card | Unexpired photo ID, one way the rule lets a bank verify |
| Proof of address, face photo | Kraken’s own choice, since the rule allows documents, other methods or both |
Why call it the bank rule? Because 31 CFR 1020.220 covers banks. Exchanges are different. FinCEN’s 2019 guidance counts an exchanger as a money transmitter, and for a money services business 31 CFR 1022.210 asks for “verifying customer identification” inside an anti-money-laundering program while naming no documents at all. So one exchange may want a utility bill and another may not, and neither breaks the rule by choosing.
Business accounts get a longer form
Opening a company account at a bank or a broker? Expect questions about the owners. Under FinCEN’s customer due diligence rule, the firm identifies and verifies “any individual who owns 25 percent or more of a legal entity, and an individual who controls the legal entity.” Ongoing monitoring is one of the rule’s four core requirements, which is why a request to refresh documents can arrive years after sign-up.
The EU version
Europe puts the duty in a directive. What counts as proof? Article 13 of Directive (EU) 2015/849 accepts documents or data from a reliable, independent source, and electronic ID qualifies. Exchanges came under it through Regulation (EU) 2023/1113, which put crypto-asset service providers on the directive’s list of financial institutions.
Firms also have to understand what an account is for and keep watching it, down to where the money comes from when the risk calls for it. Those same identity details are what the Travel Rule later attaches to each transfer.
Where the check shows up later
Limits, mostly. A verified individual at Kraken can move under $100,000 a month in cash deposits and withdrawals, according to its verification page, and the higher-limits level goes beyond that.
Checks usually take under 30 minutes, the page says, and longer if someone has to review them by hand. On November 8, 2026, it also warned that Kraken was “currently facing delays in processing new accounts” and asked people not to file several requests. Upload once, then wait.