Customer Identification Program (CIP)
What Customer Identification Program means and how CIP requirements form the foundation of identity verification.
1 min read
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
Information Collection
- 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
| Aspect | CIP | CDD |
|---|---|---|
| Origin | USA PATRIOT Act Section 326 (2001) | FinCEN CDD Rule (2016) |
| Focus | Identity verification | Risk assessment |
| Beneficial Ownership | Not required | Required |
| Ongoing Monitoring | Not explicit | 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:
- Verifying the legal entity
- Identifying beneficial owners—the KYB component