bank secrecy act / anti- money laundering (bsa/aml) compliance

Customer Identification Program• Must be written, approved by the board andincorporated in the compliance program• Must include:– Account opening procedures that specify the identifyinginformation obtained from each member; and– Reasonable and practical risk-based procedures forverifying the identity of each member– Comparison of identity with government lists• Must retain the identifying information for 5 yearsafter the account is closed– Not required to make and retain copies of photocopies, butif this is done, security must be ensured