Section 103.29(a)(2)(i)(B) of the BSA regs requires the bank to obtain and record a non-customer's SSN unless the person is an alien without an SSN, in which case you collect the alien ID number.

The wording of the regulation prevents a bank from making the sale if the person refuses to provide the information. There is no flexibility provided for persons who don't want to give their ID number.

Thank You very much.. everyone is always so helpful.

Although the "$3,000 rule" produces records that don't seem to be in too much demand by law enforcement agents, you're risking serious criticism from your regulator. This rule is a prohibition on issuance of the official item until purchasers comply with your requests for information. You are supposed to be stopping unidentified parties in their tracks, but instead your employee chose not to "guard the door" to the U. S. financial system. At a minimum, I would study the rule and schedule targetted remedial training on it for all paying and receiving personnel and their managers. If your regulator picks up this violation, I'd want to be in a position to show how I nipped it in the bud.