Financial institutions often fall prey to money launderers who exploit these platforms to funnel, mask, transfer, and cleanse ill-gotten gains. This doesn’t just endanger the specific institution but imperils the credibility of the entire financial system.
To counteract these malicious endeavours, anti-money laundering (AML) legislations such as the Bank Secrecy Act (BSA) and the USA PATRIOT Act were established. These laws are devised to thwart money laundering and other financial malefactions.
Alessa, an AML compliance platform, recently explored what what financial institutions need to know about customer identification program (CIP) rules.
The Bank Secrecy Act set the stage for Know Your Customer (KYC) obligations, which encompass customer identification and verification. The aftermath of the 9/11 terror attacks catalysed the formalisation of the customer identification program (CIP) requirements.
These obligations can be found in Section 326 of the USA PATRIOT Act. Consequently, the Financial Crimes Enforcement Network (FinCEN) in 2003 declared a rule necessitating financial institutions to implement a CIP. This decree became popularly known as the CIP rule.
Every financial institution, as per FinCEN, must possess a codified CIP seamlessly integrated into its BSA/AML compliance strategy, pending approval from the establishment’s board of directors. Essentially, a CIP is a structured procedure empowering businesses to authenticate the identity of their clientele.
Through CIP, corporations can confidently ascertain that their customers are genuine, while also predicting and understanding their potential transactions. This proactive approach assists financial entities in ensuring they are not inadvertently facilitating illegal activities, thus shielding them from legal, reputational, and operational threats.
Specifications of the CIP rule
A CIP must be equipped with account initiation methods which elucidate the sort of identification data collected from every client. Additionally, the CIP should encompass risk-driven strategies for verifying each customer’s identity as swiftly and effectively as possible post account creation. The CIP rule delineates six fundamental requisites. As long as these guidelines are adhered to, institutions can tailor their CIP to mirror their distinct characteristics like size, location, and the nature of their business operations.
Who needs to adhere to the CIP rule?
Primarily banks and other entities categorised under “financial institutions” are bound by the CIP rule’s stipulations. Over the years, this definition has broadened to include non-banking financial bodies such as credit unions, insurance entities, broker-dealers, and even casinos. However, even businesses outside this ambit can opt for customer identity verification to foster trust and transparency, enrich customer service, and bolster risk management.
The CIP rule necessitates institutions to authenticate the identity of every “customer” linked to an “account.” As per this regulation, a “customer” is typically perceived as “an individual inaugurating a new account.” However, this definition undergoes certain exceptions. Regardless of the type of interactions, the onus of abiding by the CIP rule’s prerequisites always lies with the financial institution.
Detecting money laundering can be exceedingly challenging, given its intricacy and its semblance to legitimate transactions. To combat this, Alessa presents an array of automated compliance tools tailored to help your enterprise meet CIP obligations, sidestep risky associations, and identify and avert money laundering.
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