Customer Identification Program (CIP)
Chapters in this video
- 0:00 The four mandatory data elements and the P.O. box trap
- 1:58 Identification number alternatives: U.S. persons versus non-U.S. persons
- 2:52 The TIN application exception: U.S. persons only
- 3:41 Risk-based verification methods and the unverifiable-identity workflow
- 5:09 Notice requirement, retention windows, and the five-year versus six-year trap
- 6:22 CIP, AML, and CDD: three separate BSA pillars
- 6:53 Rapid-fire exam recap
What this video covers
- The four mandatory data elements collected before account opening: name, date of birth, physical address, and identification number, and why a post office (P.O.) box alone fails the address requirement for U.S. persons
- The acceptable identification alternatives for non-U.S. persons, specifically passport number plus country of issuance, and why the TIN application exception never applies to them
- The TIN application exception for U.S. persons: confirming the application was filed before account opening and obtaining the number within a reasonable period afterward
- Risk-based verification through documentary methods, non-documentary methods, or both, and the specific two-step workflow when identity cannot be verified: close the account and consider filing a suspicious activity report (SAR)
- The customer notice requirement as disclosure, not consent, and what adequate notice looks like on the new account form
- The five-year record retention rule for CIP data after account closure, and how examiners exploit the one-year gap versus FINRA's six-year customer account record rule
- The structural separation of CIP (onboarding identity check), AML (ongoing transaction monitoring), and CDD (ongoing risk-based understanding including beneficial ownership)
Read the full lesson, free
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