Customer Identification Program Policy
The purpose of this Customer Identification Program Policy Template is to address 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:
FFIEC – Revised FFIEC BSA/AML Examination Manual
Joint Release – FinCEN and Federal Banking Agencies Clarify BSA Due Diligence Expectations for Charities and Non-Profit Customers
Joint Release – Federal Banking Agencies and FinCEN Announce Exemption from Customer Identification Program Requirements for Premium Finance Loans
Joint Press Release – Joint Statement on Bank Secrecy Act Due Diligence Requirements for Customers Who May Be Considered Politically Exposes Persons
FFIEC Press Release – Federal and State Regulators Release Updates to BSA/AML Examination Manual
Joint Press Release – Federal Agencies Issue a Joint Statement on Banks and Credit Unions Sharing Resources to Improve Efficiency and Effectiveness of Bank Secrecy Act Compliance
FinCEN Press Release – Federal Banking Agencies and FinCEN Announce Exemption from Customer Identification Program Requirements for Premium Finance Loans
FinCEN Advisory – Exceptive Relief from Beneficial Ownership Requirements for Legal Entity Customers of Rollovers, Renewals, Modifications, and Extensions of Certain Accounts
FinCEN Advisory – Extension of Limited Exception from Beneficial Ownership Requirements for Legal Entity Customers of Certain Financial Products and Services with Rollovers and Renewals
FFIEC Press Release – FFIEC Issues New Customer Due Diligence and Beneficial Ownership Examination Procedures
This Customer Identification Program Policy Template (approximately 77 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 Template – Comprehensive Version.
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