Managing Compliance With Your Customer Identification ... - IIR

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Core Four Identification Information – Core Four 1. Name Must be full legal name 2. Date of Birth, for an individual 3. Physical Address Purpose – law enforcement drop boxes 4. Identification number Must be US taxpayer id (SSN) for US Persons Application for taxpayer id
Section 326 – Customer Identification Program Basic Requirements ‣ Verify client’s identity by documentary or nondocumentary means ‣ Practical Implications ‣ Students ‣ Elderly ‣ Foreign Language ‣ Notice of verification provided to clients ‣ Maintain records of the information used to verify ‣ Core 4 - 5 years after account is closed ‣ Description of documents, verification method and resolution of issues – 5 years after the record is made ‣ Close accounts if unable to verify identity ‣ Additional Review for Certain Customers ‣ SAR filing required? ‣ Cross reference clients against lists of suspected terrorists or terrorist organizations ‣ No List so designated ‣ OFAC/SDN is a separate requirement ‣ CIP must be Risk-based
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 16 and 17: Internal Information Sources - The
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 26 and 27: CIP vs. KYC/Due Diligence • CIP i

Managing Compliance With Your Customer Identification ... - IIR

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