I'm currently a digital nomad and my bank has frozen my account when I tried to change my mailing address to a PO box due to the "Travel Rule".

My bank tells me I must show them a utility bill with my address in order to get my account unfrozen, however I have no address or utilities. How can I comply with the travel rule to get my account unfrozen?

More info: Yes, this is the travel rule in terms of the patriot act. (However I didn’t know that at the time). I discovered the bank wasn’t able to give me advice since it’s a legal issue and the bank is not authorized to give legal advice.

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    Have you asked the bank what you should do? – Nosjack Sep 26 '19 at 21:18
  • Yes. They were only able to give me the stock answer of provide an utility bill – Philippe Sep 26 '19 at 21:20
  • Did you tell them you can't give them one? – Nosjack Sep 26 '19 at 21:22
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    hence why I am here asking for advice. If my bank was actually forthcoming with information I would not need to ask here. I know other digital nomads exist and am wondering how they deal with the issue. – Philippe Sep 26 '19 at 21:26
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    "I know other digital nomads exist and am wondering how they deal with the issue." Since you asked here... I'd ask a relative to use their address. The best answers, though, would probably be on forums dedicated to the distinct issues faced by digital nomad. – RonJohn Sep 26 '19 at 21:54

The Patriot Act and related legislation (notably the Bank Secrecy Act) places regulations on financial institutions operating in the US. These laws require institutions to be able to help the government solve issues related to money laundering or funding of terrorists.

One of the components of these regulations is that institutions must retain records to prove the identities of their customers, i.e. they must implement CIPs, Customer Identity Programs. One of the identifying factors required is proof of a physical address - the regulations prohibit use of PO boxes (other than APO/FPO for armed forces). This is because a PO box makes it easy to obscure your true location - criminals often use PO boxes as a way to hide their identities.

Of course, as you've found, this makes it hard for people who do not have a permanent address.

The good news is, regulations specifically allow you to use alternatives to your own physical home address:

(3) Address, which shall be: (i) For an individual, a residential or business street address; (ii) For an individual who does not have a residential or business street address, an Army Post Office (APO) or Fleet Post Office (FPO) box number, or the residential or business street address of next of kin or of another contact individual

So - ultimately - in terms of regulation, you are allowed to use the address for a business, a next of kin, or a "contact individual" - as long as it is a physical street address, and not a PO box.

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  • This is Know Your Customer, correct? – RonJohn Sep 27 '19 at 13:50
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    @RonJohn They're definitely related. CIP is a little narrower and more focused on personal identification as a way to support future investigations or prevent fake identities in the system. KYC is broader and includes a more general sense of knowing behaviors of customers (in an attempt to capture data about fraudulent or illegal behaviors). CIP is basically, "make sure your customer isn't a bad guy" whereas KYC is more, "make sure your customer isn't doing bad things." – dwizum Sep 27 '19 at 13:55

First, I assume this is the USA based on tags.

What "Travel Rule" are they referring to?

We are fulltime RVers and move every 1-3 weeks. I use a commercial mail service in Florida.

When I went to change my address with Bank of America, it was flagged as a "commercial address" and it wouldn't be accepted. If I recall correctly, it had something to do with the Patriot Act.

The simple answer was to provide my in-law's home address as my "physical address" and then to enter a secondary "mailing address" which is my mail service.

No bank has ever requested proof of residency at the location. However, I would have my vehicle registration, other banks, insurance, and cellular bills associated with the mailing service. The closest to "utilities" is the cellular bills (one from Verizon and one from AT&T).

But it still comes down to, what is this "Travel Rule" they're referring to?

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