BSA/AML Examiner School - Case Study Oct 2023

LCB12/15

Checklist 4.2: CIP Account Review (cont.)

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If there were any discrepancies in the information obtained, did the institution either:

Y

Y NA

• Satisfactorily resolve the discrepancies prior to opening the account?

NA

NA NA

Not open the account?

•

Does the institution conduct its verification within a reasonable time? 31 CFR 1020.220(a)(2)(ii)

Y

Y

Y

Y

Y

Y

If the account was opened, was there sufficient information to allow the institution to form a reasonable belief as to the true identity of the customer? 31 CFR 1020.220(a)(2) If the information obtained from and about the customer is determined to be suspicious, was a suspicious activity report filed, if appropriate? NA

NA NA

Did the institution retain the following records: 31 CFR 1020.220(a)(3)

Y

N

Y

• All identifying information about a customer collected?

• A description of any document that was relied on for documentary verification, noting: — The type of document?

Y

Y

Y Y

— Any identification number contained in the document?

Y Y

101

Y Y

— The place of issuance?

— If any, the date of issuance and expiration date?

Y L I 3

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