BSA/AML Examiner School - Case Study Oct 2023

LCB 12/15

Checklist 4.1: CIP Policy Review (cont.)

Yes No

N/A

• A description of the methods and the results of any measures undertaken to verify the identity of the customer as non-documentary verification or as additional verification for certain signatories, for five years after the record is made? A description of the resolution of any substantive discrepancy discovered when verifying the identifying information obtained — for five years after the record is made? Does the institution provide adequate notice to its customers of its customer identification program? 31 CFR 1020.220(a)(5) Obtain and review a sample of opened accounts that were exceptions to the institution's CIP. Based on this review, is the institution effectively

Y

Y

Y

implementing its CIP? 31 CFR 1020.220(a)(1)

NA

Comments: Documentary/Non-documentary Identification — The Bank uses both documentary and non documentary identification for individuals or businesses. One primary and secondary form of identification is required for individuals. Businesses must show legal documents. Pending TINs — Request list responses indicate that the Bank does not allow accounts to be opened without a TIN. Notice of CIP — Notices are posted in the lobby and at each new account and loan desk. Indirect Lenders — Request list responses indicate that the Bank does not have any indirect dealers conducting CIP or OFAC verification on its behalf. Missing Tax Identification Numbers (TIN) — Request list responses indicate that the Bank does not have any accounts with missing TINs.

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