7/29/2004 USA PATRIOT Act Monitor News Release: Customer
Identification Program Exam Procedures Described by Bank Regulators
In a joint release of the federal bank regulators, exam procedures regarding customer identification programs are described. The release, carried on the websites of the Federal Reserve, OCC, OTS, FDIC, and the NCUA, summarizes the CIP rules of 31 CFR 103.121, and indicates that examiners, in pre-exam letters, should request lists of (1) new accounts from new customers, (2) accounts opened with an application for a TIN, (3) accounts where verification is incomplete, and (4) high-risk accounts. Examiners are to select a sample of new accounts to review for compliance with the bank's CIP. Examiners will also look at internal controls and review procedures regarding CIP being implemented for third-party and service-provider relationships.
Relevant portions of the joint release will be incorporated in the BSA checklist for banking institutions provided on the website of the USA PATRIOT Act Monitor.
The USA PATRIOT Act Monitor and the news releases prepared by the Monitor staff are services of the Civic Research Institute, publisher of Money Laundering, Terrorism, and Financial Institutions, by Raymond Banoun and John Ensminger. Contact and subscription information may be obtained at http://www.civicresearchinstitute.com/moneylaundering or by calling the Civic Research Institute at 609-683-4450 (fax: 609-683-7291).
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