Earlier this month, FinCEN and several other US financial regulators clarified how banks and credit unions can use government-issued verifiable digital credentials, including state-issued mobile driver’s licenses, to verify customers under existing Customer Identification Program rules.
Importantly, this isn't limited to someone walking into a branch.
The guidance explicitly covers accounts opened in person, remotely over the internet, or through another digital or virtual channel. The joint FAQ explains how qualifying government-issued credentials can be used within existing Customer Identification Program requirements.
This isn't a new rule. The regulators make clear that the FAQs don't change existing legal requirements or establish new supervisory expectations.
But we think the clarification matters because of what it says about how digital identity verification is evolving.
Today, proving something about yourself often means sending an organization a document and asking it to determine whether the document is genuine and the information can be trusted.
Then you move to another organization and much of that verification work happens again. A bank checks you, then an insurer, employer, marketplace or telecom provider may check much of the same information again.
The information moves, but the trust established around it doesn't easily move between organizations.
What changes with verifiable digital credentials?
The regulators describe a verifiable digital credential as a data structure containing information about an individual that is digitally signed by the issuing source, cryptographically bound to a device and protected by an activation factor such as a PIN, password or biometric.
That enables a different model.
Traditional model: “Here is a document. Please determine whether you can trust it.”
Verifiable model: “Here is the information, together with proof tied to the source that issued it.”
That doesn't eliminate the need for trust decisions. A bank still needs to ensure the credential meets its requirements and form a reasonable belief that it knows the customer's true identity.
But instead of relying entirely on inspecting a representation of a document, organizations can verify cryptographic evidence about the information they receive.
This idea goes beyond mobile driver’s licenses
The regulatory guidance is specifically about customer identity and government-issued credentials. But the underlying idea — attaching verifiable proof to information at its source — can apply much more broadly.
An insurance company could provide digital proof of coverage. An employer or certification body could provide proof of a qualification. A manufacturer could provide proof about a product. A business could provide proof that an AI agent has been authorized to perform a particular action.
These aren't use cases covered by this banking guidance, but they follow the same principle: important information becomes more useful when the recipient can independently verify where it came from and whether it has been altered.
For years, a large part of digital verification has been about building better tools to inspect documents and data after they arrive. The alternative is to make more of the information verifiable at the source.
That's why we're so focused on this problem at Dock Labs, building infrastructure that lets people, companies and AI agents share information between organizations with digital proof of where it came from and whether it has been altered.
The broader opportunity is to make trust more portable, so the receiving organization doesn't always have to rebuild it from scratch.
