New Loan - Existing Relationship

Director at a Company (USA)
     We are working on a new loan to an entity that is subject to the beneficial owner requirements. The beneficial owner has been identified as one of our existing customers. CIP was performed on the individual account in accordance with policy. However, the ID used expired in 2017. For the purpose of verifying the identity of the beneficial owner on the new loan, can I rely on the old expired DL or do I have to get a current ID since the information on file in not "up to date and accurate"? Side note - We went ahead and requested an updated DL to be on the safe side but the customer informed us that he does not have a new one. Should we allow this loan to open? What options do we have?

     Originally posted by an anonymous author with the title AVP Regulatory Compliance and Legal on 4 Mar 2019 to CBANC FI Professionals Community.