Customer Identification Program – Checklist and Requirements
When completing CIP tasks, AML Compliance Officers sometimes use a Customer Identification Program checklist to ensure completion of all required tasks.
- Developing a Well-Defined Customer Identification Program (CIP)
- AML KYC Onboarding Lifecycle Process Flow
- AML Periodic Reviews for Low, Medium, and High-Risk Clients
- KYC vs. CIP vs. CDD | Know Your Customer Rules and Guidelines
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Sample Customer Identification Program Checklist
Below is a high-level CIP checklist for ensuring CIP completion.
The staff member performing these tasks may vary across firms.
CIP Checklist for New Customers
|Front Office / Sales Team||Notify AML staff of a new client in the pipeline|
|AML Staff||Review preliminary information provided by FO/Sales regarding the new client (i.e., client type, product/service client is looking to receive from the firm, client location, etc.)|
|AML Staff||Create the customer profile to track the customer during the onboarding process (use a Case Management AML Tool or use Excel)|
|AML Staff||Determine which AMK KYC documentation is needed|
|AML Staff||Notify FO/Sales of AML KYC information and documentation needed from the new client or reach out directly to the new client|
|FO/Sales||Contact new client to request required documentation and information|
|Client||Provide required documentation and information|
|FO/Sales||Receive required documentation and information|
|FO/Sales||Send required documentation and information to AML staff|
|AML Staff||Receive required documentation and information|
|AML Staff||Initiate document tracking|
|AML Staff||Kick off AML BSA assessment|
|AML Staff||Validate customer identity using documentary or non-documentary KYC verification methods|
|AML Staff||Conclude CIP customer identity screening|
|AML Staff||Conduct sanctions / OFAC screening|
|AML Staff||Identify sanctions screening matches as true or false or no match|
|AML Staff||Investigate any positive matches to validate positive match|
|AML Staff||Prepare escalation documents (as needed) – for positive matches|
|AML Staff||Escalate true matches to Chief AML Officer, AML Head, or equivalent|
|Chief AML Officer||Review escalation document and perform additional screening (i.e., EDD) as needed|
|Chief AML Officer||Approve or reject high risk customer|
|AML Staff||If no sanctions screening match, continue with the below set of activities|
|AML Staff||Perform customer due diligence|
|AML Staff||Perform customer risk rating|
|AML Staff||Record risk rating results|
|AML Staff||Escalate high risk clients to Chief AML Officer|
|AML Staff||Open account for low or medium-risk clients|
This review checklist has been developed to help Compliance Officers, AML Specialists, and other regulatory compliance professionals in developing well-defined and well-documented Anti-Money Laundering (AML) programs.
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