On January 12th, the Financial Crimes Enforcement Network published its November 3, 2009 Ruling on customer identification requirements as they relate to customers who are issued a post office box address as part of their participation in a state-run address confidentiality program ("ACP"). In an effort to support states that have established an ACP, FinCEN authorizes the following exception to the requirement that a financial institution obtain a customer's residential or business street address: a customer who participates in a state-created ACP shall be treated as not having a residential or business street address and a secretary of state, or other state entity serving as a designated agent of the customer consistent with the terms of the ACP, will act as another contact individual for the purpose of complying with FinCEN's rules. Therefore, a financial institution should collect the street address of the ACP sponsoring agency for purposes of meeting its CIP address requirement. FIN-2009-R003.