BSA/AML – Customer Identification Program (CIP)
USC - Federal Law, US Patriot Act, FinCEN
The Customer Identification Program (CIP) came into play with the passing of the USA PATRIOT Act. If you have been around the world of BSA compliance for a while you may remember banks trying to fight this level of regulation, prior to 2001. The information required was being obtained, for the most part, but the additional requirements to mandate such collection was not favorably received. It requires the implementation of an identification program that is appropriate to the size and risk level of the institution, along with providing consideration for minimum requirements.
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