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Customer Identification Program

Mon, Jul 28, 2014

Columbia, Maryland

Section 326 of the USA Patriot Act sets forth minimum standards for financial institutions, including credit unions, for the identification and verification of the identity of any customer/member opening an account (12 CFR §103.121).

The written customer/member identification program (CIP):

  • Must be a part of the credit union’s anti-money laundering program
  • Must be approved by the board
  • Should be tailored to the credit union’s size, location, and type of business

Members must be provided notice that the credit union is verifying their identity and why. The CIP must, at a minimum, provide for:

  • Obtainment of certain basic identifying data
  • Verification of the identity of each customer to the extent reasonable and practicable
  • Maintenance of records of the information used to verify the identity
  • Determination of whether the customer/member appears on any lists of suspected terrorists provided by the federal government

For additional information to help your credit union stay in compliance, visit the Customer Identification Program topic on the Bank Secrecy Act channel of InfoSight.