Customer Identification Program Policy
This Customer Identification Program Policy addresses the Customer Identification Program (CIP) of a bank, credit union, fintech company, or other type of financial institution in order to adhere to Section 326 of the USA Patriot Act regarding the requirement to implement reasonable procedures to verify the identity of any person.
Table of Contents
- Purpose and Contents – Topic 1
- Policy Statement – Topic 2
- Definitions – Topic 3
- Structure of Accountability – Topic 4
- Customer Due Diligence Program – Topic 5
- Minimum Identity Verification Standards – Topic 6
- Procedures for Verification of Identity – Topic 7
- Procedures for Lack of Identity Verification – Topic 8
- Rules for Special Accounts, Persons and Other Entities – Topic 9
- Additional Account Opening Procedures – Topic 10
- Comparison with Government Lists – Topic 11
- Information Sharing Procedures – Topic 12
- Exemptions – Topic 13
- Other Legal Requirements – Topic 14
- Use of Third-Parties – Topic 15
- Customer Notice Procedures – Topic 16
- Audit Policy – Topic 17
- Staff Training – Topic 18
- Retention of Documentation – Topic 19
Includes the following form templates:
- BSA Certification for Beneficial Owners Form (2 pages)
- BSA CIP New Customer Information Sheet (1 page)
Recent updates to this product:
11/04/24 Update
FinCEN Final Rule – Update to the Public Utility Exemption Under the Beneficial Ownership Information Reporting Rule
03/04/24 Update
FinCEN Final Rule – Beneficial Ownership Information Access and Safeguards
12/04/23 Update
FinCEN Final Rule – FinCEN Extends Deadline for Companies Created or Registered in 2024 to File Beneficial Ownership Information Reports
11/15/23 Update
FinCEN Final Rule – FinCEN Finalizes Rule on Use of FinCEN Identifiers in Beneficial Ownership Information Reporting
08/15/23 Update
FFIEC Announcement 2023-02 – Federal and State Regulators Release Updates to the BSA/AML Examination Manual
10/17/22 Update
FinCEN Final Rule – Beneficial Ownership Information Reporting Requirements
07/05/22 Update
FinCEN – Statement on Bank Secrecy Act Due Diligence for Independent ATM Owners or Operators
This Customer Identification Program Policy (approximately 104 pages) is available to purchase from BankPolicies.com in Microsoft® Word format.
NOTE: The complete contents of this product are also included in the Bank Secrecy Act Policy – Comprehensive Version.
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