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Run: CIP Customer Identification Verification Checklist

Use this CIP Customer Identification Verification Checklist to confirm the required identity data, verification evidence, screening, and recordkeeping at acc...

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Inspection Scope and Account Opening Context

Record the account type, channel, and opening date for the file under review.
Identify the internal CIP policy, procedure, or SOP version used for this account-opening review.
Verify the inspection is being performed against the institution's CIP requirements under 31 CFR 1020.220.

Required Customer Identity Information

Verify the file contains the customer's full legal name as required by CIP.
Verify date of birth was collected for an individual customer where applicable.
Verify the customer address was collected in accordance with CIP requirements and internal procedures.
Verify the file contains an identification number such as SSN, TIN, passport number, or other permitted identifier as applicable.

Verification Method and Evidence

Select the primary verification method used for identity verification.
Verify the evidence reviewed reasonably supports the name, date of birth, address, and identification number on file.
Verify any mismatch, deficiency, or non-conformance was resolved or escalated before the account was opened.
Verify identity was verified within the institution's CIP timeframe for account opening and any provisional account controls.

Recordkeeping and Retention

Verify required CIP records are retained and retrievable per policy and regulatory requirements.
Verify the file includes the source documents, system records, or verification results used to support the identity decision.
Enter the retention period applied to the CIP record in months.

Screening, Escalation, and Final Disposition

Verify the customer was screened against applicable government lists or sanctions/watchlist controls per institution procedure.
Verify any alert, potential match, or exception was escalated to compliance or the designated reviewer.
Select the final disposition of the CIP review.
Indicate whether any deficiency, non-conformance, or control gap requires corrective action.

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