Introductory BSA/AML Examiner School, Atlanta, CA

individual/entity when establishing the relationship. The CIP procedures are a critical step to ensure that this financial institution does not establish a relationship with an unreliable or criminal party. Anytown Community Bank will develop, implement, and maintain detailed procedures to direct staff in verifying person(s) creating a new customer relationship. The corresponding CIP procedures will specify the types of identifying information to be obtained by staff. Verification procedures will also be created and implemented to verify the accuracy and validity of select account opening documentation provided to the bank. These procedures will be reasonable, practical, and risk-based. The CIP procedures will address requesting the following information: Minimum Customer Identifying Information Required Prior to Opening a New Account: • Legal Name. • Date of Birth (Individuals). • Physical Address: o Place of residence (Individuals). o Principal place of business (Non-individuals). o Persons in the military on active duty – Army Post Office (APO), Fleet Post Office (FPO), or residential or business address of next of kin or other contact individual. • Identity Number: U.S. Persons - o Social Security Number (SSN) or other Taxpayer Identification Number (TIN) for an individual. o Employer Identification Number (EIN) or other Taxpayer Identification Number (TIN) for separate legal entities (Corporation, Partnership, Trust, etc.). Non-U.S. Persons – o One or more of the following: • U.S. TIN. • 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. Management is authorized to establish procedures to obtain other types of information from customers seeking to open new accounts that are consistent with industry best practices as well as safe and sound operations. The CIP regulation allows an institution to establish procedures for opening an account for a customer that has applied for, but has not yet received, a TIN. In this case, management must include procedures in the CIP to confirm that the TIN application was filed before the customer opens the account, and to ensure that the bank obtains the taxpayer identification number within a reasonable period of time. In the absence of a specific regulatory definition of “reasonable period of time”, the bank will allow a period of 60 days from the date an account is opened for a customer to obtain a TIN. Procedures will be established to monitor that a TIN is ultimately received, and to close the account if a TIN is not received within 60 days. Verification Methods The timely, accurate verification of a customer’s identity is of significant importance to both the financial institution and the customer. However, depending on the types of documentation provided and detailed, whether the customer was present, and when the account was opened will impact the verification options and time frames. Ideally, customer identity should be verified at the time the account is opened. If verification at the time of account opening is not possible or practicable, management must implement