Managing Compliance With Your Customer Identification ... - IIR

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Internal Information Sources – The Details: Identify and inventory the types of lists and how used Determine practice standards for lists and key events : •Appearance on government list, •Filing of suspicious activity report, •Account closure or termination of relationship •Receipt of criminal subpoena •Involvement in loss or fraudulent transaction •Subject of internal investigation •Negative press (financial or otherwise)
Internal Information Sources – The Details:(continued): Practices around keeping lists current Extent of detailed information added to lists Review and approval for changes to lists Balance internal sharing and “tipping-off” risk Information security, privacy and data sharing Technology and workflow
Page 1 and 2: Managing Compliance With Your Custo
Page 4 and 5: Customer Identification Program is
Page 6 and 7: When are CIP and KYC complete? a) O
Page 8 and 9: When are CIP and KYC complete? a) O
Page 10 and 11: At Account Opening: ‣Determine ap
Page 12 and 13: Screening Capabilities: Enable effi
Page 14 and 15: External Information Sources •Com
Page 18 and 19: Summary CIP and KYC is an ongoing e
Page 20 and 21: Definition of Customer includes: De
Page 22 and 23: Recent Guidance Agent Lending - Apr
Page 24 and 25: Core Four Identification Informatio
Page 26 and 27: CIP vs. KYC/Due Diligence • CIP i

Managing Compliance With Your Customer Identification ... - IIR

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