Top BSA Violations: CIP
At our Virtual BSA/AML Conference in November, there was a session on “Top BSA / AML Violations & Audit Tips” that have been noted by our Review Team. One topic on that list was the Customer Identification Program (CIP). CIP has been around for a long time now and, for the most part, your program runs smoothly without a lot of fuss. Sometimes with these long-standing compliance requirements, however, people can get complacent and little things start to slip through the cracks. With CIP, we often see this happening with the overall documentation. In a nutshell, CIP is a two-step process, you must identify a person by asking them for certain information and then you must verify it. Oftentimes, we see employees unknowingly turning this into a one step process.
Kevin explains more in the video:
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Published
2024/12/03
Kevin Edwards
Kevin brings years of experience and a unique perspective on regulatory matters to our clients. A self-proclaimed geek and accredited CRCM, Kevin is also a recovering attorney with experience as in-house counsel for a large regional bank and one of the leading national title insurance providers. For reasons unknown, Kevin decided to leave the safety and serenity of his desk job to seek fortune and glory as a wandering adventurer. Like a bank compliance version of Kwai Chang Caine, The Man with No Name or Don Quixote, he now travels the land seeking to help those in need and righting compliance wrongs, wherever he may find them. Kevin lives in Sioux Falls with his two children, who are surprisingly normal after having endured their father’s vivid imagination for their entire lives. He won’t admit to having any hobbies, because apparently “Regulations never sleep.” (While he does say this in his Batman voice, we’re pretty sure he’s joking.) From the looks of his Facebook page, he likes the outdoors and spending time with his large extended family (who seem like relatively normal people).