Customer Identification Program – Checklist and Requirements


Section 326 of the USA Patriot Act requires financial institutions to develop detailed Customer Identification Programs as part of each firm’s AML and Bank Secrecy Act (BSA) compliance programs.

When completing CIP tasks, AML Compliance Officers sometimes use a Customer Identification Program checklist to ensure completion of all required tasks. 

See Also:

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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

Staff

Activity/Tasks

Done? Y/N

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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