Customer Identification Program (CIP)

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)