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:
The new exam procedures cover audit and training programs to ensure that your institution has adequately incorporated a CIP. Your CIP must contain:
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 www.federalreserve.gov/boarddocs/srletters/2005/SR0509.htm. For more information, contact Jeff Bock at 1-800-333-0810, ext. 44-8835.