Customer Screening and Identification

What this video covers

• The USA PATRIOT Act requirement for a written Customer Identification Program (CIP) as part of the broader anti-money laundering (AML) compliance program
• The four exact CIP items: name, date of birth, address, and identification number, and why occupation, income, and net worth belong to suitability, not CIP
• Why a post office box alone fails as an individual CIP address and what qualifies as a sufficient current physical address
• The two verification methods, documentary versus non-documentary, and why firms need only one to form a reasonable belief
• The exact representative protocol on an Office of Foreign Assets Control (OFAC) hit: stop, escalate to AML compliance, and do not tip off the customer
• The 5-year record retention rule and the critical distinction between when the clock starts for CIP identifying information versus verification records