A Customer Identification Program (CIP) is a US regulatory requirement under the Bank Secrecy Act mandating financial institutions to verify the identity of individuals opening accounts.
CIP Requirements
- Name
- Date of birth
- Address
- Identification number (SSN for US persons; passport/other for non-US)
Verification Methods
- Documentary: Government-issued ID review
- Non-documentary: Database verification, credit bureau checks
- Combination: Multiple methods for higher confidence
Additional Requirements
- Check against government lists
- Maintain records of verification procedures
- Notify customers of identification requirements
CIP vs. CDD
Origin
- CIP: USA PATRIOT Act Section 326 (2001)
- CDD: FinCEN CDD Rule (2016)
Focus
- CIP: Identity verification
- CDD: Risk assessment
Beneficial Ownership
- CIP: Not required
- CDD: Required
Ongoing Monitoring
- CIP: Not explicit
- CDD: Explicit
CIP establishes the baseline; CDD builds on it with deeper understanding and risk assessment.
CIP for Business Accounts
For business accounts, CIP extends to:
Related: KYC | BSA | CDD