Customer Identification Program – Checklist and Requirements
Section 326 of the USA Patriot Act requires financial institutions to develop detailed Customer Identification Programs as part of each firm’s AML and Bank Secrecy Act (BSA) compliance programs.
When completing CIP tasks, AML Compliance Officers sometimes use a Customer Identification Program checklist to ensure completion of all required tasks.
See Also:
- Developing a Well-Defined Customer Identification Program (CIP)
- AML KYC Onboarding Lifecycle Process Flow
- AML Periodic Reviews for Low, Medium, and High-Risk Clients
- KYC vs. CIP vs. CDD | Know Your Customer Rules and Guidelines
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Sample Customer Identification Program Checklist
Below is a high-level CIP checklist for ensuring CIP completion.
The staff member performing these tasks may vary across firms.
CIP Checklist for New Customers
| Staff | Activity/Tasks | Done? Y/N |
| Front Office / Sales Team | Notify AML staff of a new client in the pipeline | |
| AML Staff | Review preliminary information provided by FO/Sales regarding the new client (i.e., client type, product/service client is looking to receive from the firm, client location, etc.) | |
| AML Staff | Create the customer profile to track the customer during the onboarding process (use a Case Management AML Tool or use Excel) | |
| AML Staff | Determine which AMK KYC documentation is needed | |
| AML Staff | Notify FO/Sales of AML KYC information and documentation needed from the new client or reach out directly to the new client | |
| FO/Sales | Contact new client to request required documentation and information | |
| Client | Provide required documentation and information | |
| FO/Sales | Receive required documentation and information | |
| FO/Sales | Send required documentation and information to AML staff | |
| AML Staff | Receive required documentation and information | |
| AML Staff | Initiate document tracking | |
| AML Staff | Kick off AML BSA assessment | |
| AML Staff | Validate customer identity using documentary or non-documentary KYC verification methods | |
| AML Staff | Conclude CIP customer identity screening | |
| AML Staff | Conduct sanctions / OFAC screening | |
| AML Staff | Identify sanctions screening matches as true or false or no match | |
| AML Staff | Investigate any positive matches to validate positive match | |
| AML Staff | Prepare escalation documents (as needed) – for positive matches | |
| AML Staff | Escalate true matches to Chief AML Officer, AML Head, or equivalent | |
| Chief AML Officer | Review escalation document and perform additional screening (i.e., EDD) as needed | |
| Chief AML Officer | Approve or reject high risk customer | |
| AML Staff | If no sanctions screening match, continue with the below set of activities | |
| AML Staff | Perform customer due diligence | |
| AML Staff | Perform customer risk rating | |
| AML Staff | Record risk rating results | |
| AML Staff | Escalate high risk clients to Chief AML Officer | |
| AML Staff | Open account for low or medium-risk clients |
This review checklist has been developed to help Compliance Officers, AML Specialists, and other regulatory compliance professionals in developing well-defined and well-documented Anti-Money Laundering (AML) programs.
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