USA PATRIOT Act Disclosure
Last Updated: April 21, 2026
Important Notice: To help the government fight the funding of terrorism and money laundering activities, federal law requires all financial institutions to obtain, verify, and record information that identifies each person who opens an account. Banking services are provided by Grasshopper Bank, N.A., Member FDIC. This disclosure applies to all accounts opened through the SkyFi platform.
What the Law Requires
Section 326 of the USA PATRIOT Act requires financial institutions to implement a Customer Identification Program (CIP) as part of their Bank Secrecy Act compliance obligations. This requirement applies to all financial institutions that open accounts for customers.
"To help the government fight the funding of terrorism and money laundering activities, Federal law requires all financial institutions to obtain, verify, and record information that identifies each person who opens an account. What this means for you: When you open an account, we will ask for your name, address, date of birth, and other information that will allow us to identify you. We may also ask to see your driver's license or other identifying documents."
Individual Customer Requirements
Required Information
When opening an account as an individual, we are required to collect and verify the following:
Full legal name
As it appears on government-issued ID
Date of birth
To verify identity and age
Physical address
Residential or business address (no P.O. Box)
Identification number
Social Security Number (SSN) or Individual Taxpayer Identification Number (ITIN)
Identity Verification
We verify your identity using documentary methods (e.g., driver's license, passport) and non-documentary methods (e.g., database checks, credit bureau data). You may be asked to provide a copy of a government-issued photo ID.
Business Customer Requirements
Business Entity Information
For business accounts, we collect information about the entity and its beneficial owners:
- Legal business name and any DBAs
- Principal place of business address
- Employer Identification Number (EIN)
- Business formation documents (articles of incorporation, operating agreement, etc.)
- Business purpose and nature of operations
- Anticipated transaction volume and types
Beneficial Ownership Requirements (FinCEN CDD Rule)
Under FinCEN's Customer Due Diligence (CDD) rule, we are required to identify and verify the identity of beneficial owners of legal entity customers. A beneficial owner is any individual who:
- Owns 25% or more equity interest in the legal entity (Ownership Prong)
- Controls significant responsibility to manage the legal entity (Control Prong) — typically a CEO, CFO, COO, Managing Member, or equivalent
Corporate Transparency Act (CTA) — Beneficial Ownership Information
Separately from bank CDD requirements, the Corporate Transparency Act (effective January 1, 2024) requires most U.S. legal entities to file Beneficial Ownership Information (BOI) reports directly with FinCEN. This is a federal obligation of your company — not of SkyFi or Grasshopper Bank — but we may request confirmation of compliance as part of our due diligence. For more information and to file, visit www.fincen.gov/boi.
Verification Process
Information Collection
During account opening, you will be asked to provide identifying information through our secure onboarding flow. All information is transmitted using bank-grade encryption.
Documentary Verification
You may be required to upload copies of government-issued identification documents. Accepted documents include U.S. driver's licenses, state ID cards, and U.S. or foreign passports.
Non-Documentary Verification
We also use automated database checks, including credit bureau inquiries and identity data providers, to verify the information you provide without requiring physical documents in all cases.
Ongoing Monitoring
We are required to conduct ongoing monitoring of account activity to identify and report suspicious transactions. We may periodically request updated information to maintain accurate records.
When We Cannot Verify Your Identity
If we are unable to verify your identity, we may take one or more of the following actions:
Request additional identifying information or documentation
Restrict account activity until verification is completed
Decline to open or maintain the account
File a Suspicious Activity Report (SAR) as required by law
Close an existing account
Confidentiality and Use of Information
All information collected as part of our Customer Identification Program is maintained securely and used solely for regulatory compliance purposes. We do not share this information for marketing purposes.
We may be required to share information with law enforcement, regulatory agencies, or other financial institutions as required or permitted by law, including in connection with the detection and prevention of financial crimes.
Banking Services Provider
Banking services, including deposit accounts and payment processing, are provided by Grasshopper Bank, N.A., Member FDIC. Grasshopper Bank maintains its own Customer Identification Program in compliance with the USA PATRIOT Act and applicable federal regulations.
SkyFi operates as a technology platform and financial services provider. SkyFi is not a bank. Grasshopper Bank is the chartered financial institution responsible for maintaining regulatory compliance with the Bank Secrecy Act, USA PATRIOT Act, and related AML/KYC requirements.