Introductory BSA/AML Examiner School, Providence, RI

Risk Assessment

The CIP Rule*: (2) Identity Verification Procedures. • Must be based on the bank’s assessment of relevant risks including those presented by:  Types of accounts,  Methods for opening accounts,  Types of identifying information available,  Bank’s size,  Bank’s location,  Bank’s customer base.

* 31 CFR 1010.220

Risk Assessment Customer Identification Program

– Account Opening Procedures

– Verifying procedures

– Products and Services analysis