Customer Identification Programs: Compliance, Operations, and Audit

Authors: Regulatory Compliance Associates, Inc. (REGCOM)
Format/Frequency of Update: Looseleaf with CD/Two 2 updates annually
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CIP compliance made simple!

One of the compliance challenges under the USA PATRIOT Act is the mandate under Section 326 that all financial institutions establish a Customer Identification Program (CIP). The CIP regulations require institutions to implement reasonable procedures for:

Verifying the identity of any person seeking to open an account, to the extent reasonable and practicable
Maintaining records of the information used to verify the person’s identity, including name, address, and other identifying information
Determining whether the person appears on any lists of known or suspected terrorists or terrorist organizations provided to the financial institution by any government agency

To help you and your staff with CIP compliance, we’ve developed Customer Identification Programs: Compliance, Operations, and Audit to help where you need it most.

Assess and improve your existing CIP

Customer Identification Programs provides you with the tools (checklists, internal audit control procedures, regulatory exam procedures) you need to assess your existing CIP, and find areas you can improve. It’s a comprehensive, ongoing resource for complying with the CIP rules.

In particular, you’ll find extensive resources for training staff on the new requirements and procedures, including a sample training plan outline, course agenda, PowerPoint™ presentation, money laundering case studies, and quiz.

With your subscription, you’ll receive complete information on the CIP rules and Section 326 of the USA PATRIOT Act, plus an analysis of how they relate to the BSA and anti-money laundering in general, and to OFAC requirements. Future Updates will focus on analyses of new regulatory issuances and offer examples of how financial institutions were cited in compliance exams.

Get ready for BSA audits and examinations

In-depth internal audit work program with supporting internal controls questionnaire
Sample examination procedures that reflect "typical" examination approaches to a review of CIP elements of an institution’s BSA/AML program.
An in-depth questionnaire to further assist BSA Officers in preparing for the next onsite examination

Train your financial institution’s staff to stay in compliance

Ready-to-run PowerPoint™ Presentation for in-house CIP Training activities
Suitable for all employees
Supporting training guidance and handouts
Additional quiz material

Practical tools let you hit the ground running

Detailed implementation checklists
Decision points/analysis review chart to help your management team develop an institution-wide CIP program
Sample CIP policy for passage by your Board of Directors, including expanded direction regarding governance oversight
Detailed sample CIP procedures, ready for adaptation and implementation by your financial institution, reflecting revised final language, as well as insights on additional best practices
Extensive guidance on sample techniques to consider for verification of documentation
Staff guidance-– tip sheets for frontline and back-office staff
Accompanying CD includes the full text of the manual for easy customization

Simplify your research on CIP issues

Detailed review of the final implementing requirements, with supporting expert analysis
Extensive discussion and analysis of each section of the new implementing regulation
Directive profiles of each federal regulatory agency’s implementing language for the CIP requirements
The text of the final regulations

Gain additional BSA insights

New resource list to assist BSA Officers not only in tackling CIP implementation, but also in meeting ongoing BSA/AML challenges
Insights on potential problem areas
Cited violations and enforcement actions
Recaps of past breakdowns in BSA/AML systems
Insights on future BSA/AML changes

About the Authors

Regulatory Compliance Associates, Inc. (REGCOM), one of Sheshunoff’s most popular authors, is headed by Jerry Miller, a former OCC field examiner and member of the OCC Regional/District management team. After his work in the public sector, where he still maintains a network of strong insider contacts, Mr. Miller served as practice leader for KPMG Peat Marwick’s Financial Institutions Regulatory Compliance Consulting Practice group. In this role, Mr. Miller advised management and directorates of financial institutions on understanding and complying with regulations. In addition, Mr. Miller and his associates designed and implemented individual regulatory compliance programs for financial institution clients of all asset sizes.

REGCOM’s professionals have financial, regulatory, and problem bank assistance expertise, and have participated in developing and implementing federal banking regulatory agency policies and guidelines pertaining to various aspects of banking. In addition, REGCOM’s staff members have written numerous articles on compliance and banking, and they are frequent lecturers at financial institution conferences. They are the authors of Sheshunoff’s Bank Policies, Procedures, and Internal Audit services, among other titles.

Get the best CIP guidance available

Order your copy of Customer Information Programs: Compliance, Operations, and Audit today. To order, just click on the "order now" button above. If you’d prefer, you may order by phone at 800-456-2340, or by e-mail at info.sis@sheshunoff.com.