BSA/AML Examiner School - Case Study Oct 2023

LCB12/15

Checklist 4.1: CIP Policy Review (cont.)

Yes No

N/A

• Is the customer required to have applied for a TIN prior to opening the account? • Does the institution confirm that an application was filed prior to opening the account? Do the procedures describe when the institution will use documents, non documentary methods, or a combination of both methods to verify the customer's identity? 31 CFR 1020.220(a)(2)(ii) Do the documentary verification procedures describe when the institution will verify identity through documents (i.e., identification documents) and establish the documents that will be accepted for this purpose? 31 CFR 1020.220(a)(2)(ii)(A) Do the non-documentary methods describe when these methods will be used in addition to, or instead of, relying on documents? 31 CFR 1020.220(a)(2)(ii)(B) Do the CIP procedures on non-documentary methods address the following situations: 31 CFR 1020.220(a)(2)(ii)(B)(2) • An individual is unable to present an unexpired government-issued identification document that bears a photograph or similar safeguard?

NA

NA

Y

Y

Y

y

• The institution is not familiar with the documents presented?

Y

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