Regulatory Alerts2004-01-08
Added
Guidance on Customer Identification Regulations Financial Crimes Enforcement Network FAQs: Final CIP Rule
The Agencies issue frequently asked questions regarding the application of 31 C.F.R. § 103.121, which implements section 326 of the USA PATRIOT Act and requires banks, savings associations, credit unions, and certain non-federally regulated banks to maintain a Customer Identification Program. The guidance clarifies that the rule applies to formal banking relationships such as loans and deposit accounts, defining the customer as the person opening the account, while excluding foreign subsidiaries and non-bank holding companies from the specific bank CIP rule. Banks are required to implement risk-based procedures to verify customer identity and must ensure compliance for new accounts, including those opened by minors or through assumed loans, though existing account holders are exempt upon renewal if identity is already known.