BSA/AML Examiner School Case Study

Internal Use Only

• New Customer: Is an individual or legal entity that is opening a new account with the bank. It also means an individual who is opening a new account for another individual who lacks legal capacity (such as a minor or an incompetent) or for a group that has not formed a legal entity (such as a civic club). In the case of a joint account, each of the accountholders who does not already have an account here is considered new customer. o A new customer is an individual who obtains a loan with the Bank. In the case of a joint loan, it means each of the borrowers who do not already have an account here. The customer identification program (GIP) rules apply only to those individuals who actually close on a loan; they do not apply to people who apply but are subsequently denied or withdraw their application. • Existing Customers: o If a customer has an existing account with the Bank, the Bank employee must determine if the account was in place prior to October 1, 2003. If so, the Bank employee must determine if the information in the CIF is current and add any additional information, such as a driver's license number, state of issuance, expiration date or copy of ID. o If this customer opened an account after October 1, 2003, the Bank employee must determine if all of the identification information was obtained by the new accounts person. If a reasonable belief cannot be concluded, then the CIP process must be completed for that customer. • Customer Identification: Bank personnel should first refer to the Bank's CIP requirements. At a minimum, the Bank must obtain the following information to validate the true identity of an individual or entity seeking to open an account: o Name o For individuals, date of birth o Address:  Individual — residential or business street address  Individual who does not have a residential or business street address — an Army Post Office or Fleet Post Office box number, or the residential or business street address of next of kin or another contact individual o Entity - For persons other than individuals, (i.e., corporations, partnerships, and trusts) principal place of business and, if different, mailing address. o Identification Number:  U.S. Person - a U.S. taxpayer identification number (i.e.., social security number, individual taxpayer identification number, or employer identification number); or  Non-U.S. Person - one or more of the following: A taxpayer identification number; Passport number and country of issuance; Alien identification card number; Number and country of issuance of any other government issued document evidencing nationality or residence and bearing a photograph or similar safeguard. [A copy of the Primary Identification documents (passport, ID) must be obtained and scanned / copied for Imaging] Note: In the case of an elderly customer, Minor, and Law enforcement that cannot produce the required documents, refer to the listing CIP Matrix for a list of identifications that may be produced for verification purposes.

For Training Purposes Only

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