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Regulators Create Exam Procedures for Reviewing Customer Identification Programs

Thursday, January 1, 2004

Federal banking agencies have issued Bank Secrecy Act examination procedures to review customer identification programs (CIPs) for all accounts opened on or after Oct. 1, 2003. During each examination, examiners will be reviewing your institution's CIP to ensure that it:

  • is appropriate for your bank's size, location and risk profile;
  • meets certain minimum standards; and
  • provides adequate internal controls and compliance with applicable regulations.

The new exam procedures cover audit and training programs to ensure that your institution has adequately incorporated a CIP. Your CIP must contain:

  • detailed account-opening procedures that verify each customer's identity and that notify the customer of the verification process;
  • review procedures to ensure your institution complies with record-keeping requirements;
  • review procedures that check new accounts against federal government lists of known or suspected terrorists; and
  • guidance and procedures about when to file a suspicious activity report.

Examiners also will review a sample of new accounts to test internal controls and compliance with regulations. If your institution relies on a third party for part of the CIP, examiners will review the relationship between the third party and your institution to ensure that it is reliable and contains appropriate internal controls and review procedures.

A copy of the CIP examination procedures is available at For more information, contact Jeff Bock at 1-800-333-0810, ext. 44-8835.