Introductory BSA/AML Examiner School, Atlanta, CA

Risk Assessment

The CIP Rule*:

(2) Identity Verification Procedures. • Must be based on the bank’s assessment of relevant risks including those presented by: ➢ Types of accounts, ➢ Methods for opening accounts, ➢ Types of identifying information available, ➢ Bank’s size, ➢ Bank’s location, ➢ Bank’s customer base.

* 31 CFR 1010.220

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Risk Assessment

Customer Identification Program

– Account Opening Procedures

– Verifying procedures

– Products and Services analysis

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