Creating a Customer Identification Program policy from scratch requires extensive knowledge of USA PATRIOT Act requirements, OFAC screening obligations, and recordkeeping mandates. Compliance officers and legal teams spend hours researching regulatory requirements, drafting verification procedures, and ensuring all mandatory elements are properly addressed—time that could be spent on strategic compliance initiatives.
Creating a comprehensive Customer Identification Program policy that satisfies USA PATRIOT Act requirements is time-consuming and complex. Compliance officers spend days researching regulations, drafting procedures, and ensuring every requirement under 31 CFR 1020.220 is addressed while maintaining practical usability for staff.
CaseMark automates CIP policy creation with AI-powered drafting that incorporates current regulatory requirements, examination guidance, and industry best practices. Generate board-ready, examination-proof policies in minutes with complete coverage of verification methods, recordkeeping, risk assessment, and governance requirements.
This workflow is applicable across multiple practice areas and use cases
Financial institutions, fintech startups, and money services businesses need compliant CIP policies as part of their initial regulatory framework during formation and licensing.
Corporate formation attorneys working with financial services clients must ensure BSA/AML compliance from inception, making CIP policy creation a critical deliverable during the formation process.
Board members and corporate governance advisors of financial institutions must ensure proper CIP policies are adopted and maintained as part of their fiduciary oversight responsibilities.
Corporate governance in regulated financial institutions requires board-level approval and oversight of compliance policies, including CIP requirements mandated by federal law.
During M&A due diligence of financial institutions, buyers need to review and potentially update CIP policies to ensure regulatory compliance and identify potential liabilities.
M&A attorneys must assess compliance programs including CIP policies when evaluating financial institution targets, and may need to harmonize policies post-acquisition.
VC and PE firms investing in fintech companies need to ensure portfolio companies have compliant CIP policies to mitigate regulatory risk and protect investment value.
Investors in financial services companies conduct regulatory compliance diligence and often require portfolio companies to implement or update CIP policies as a condition of investment or value creation initiative.
The generated policy covers all requirements under Section 326 of the USA PATRIOT Act and 31 CFR 1020.220, including customer identification information collection, identity verification methods (documentary and non-documentary), government list screening, risk-based procedures, recordkeeping and retention, customer notice requirements, and program governance. It also addresses beneficial ownership requirements under the Customer Due Diligence Rule and integration with broader BSA/AML compliance programs.
Yes, the policy is fully customizable based on your institution's profile, risk assessment, and operational structure. Whether you're a community bank, credit union, broker-dealer, or fintech company, the generated policy adapts to your specific products, customer base, geographic footprint, and risk factors. You can incorporate your existing procedures, examination findings, and institutional terminology.
The policy incorporates current examination guidance from FinCEN, FFIEC BSA/AML examination procedures, and federal banking agency standards. It includes all elements examiners look for: clear procedures, risk-based approaches, adequate recordkeeping, proper governance, and staff training requirements. The policy uses precise regulatory citations and addresses common examination findings to demonstrate robust compliance.
The policy provides detailed procedures for both documentary verification (examining government-issued IDs, passports, licenses) and non-documentary verification (database checks, customer contact, reference verification). It includes guidance for verifying individuals and legal entities, handling special circumstances, resolving discrepancies, and applying risk-based enhanced due diligence. Specific instructions help staff know exactly what documents to examine and how to document verification activities.
Yes, the policy includes comprehensive provisions for relying on third-party service providers or other financial institutions to perform CIP functions. It covers required contractual provisions, due diligence procedures, ongoing oversight responsibilities, and documentation requirements. The policy clarifies that ultimate compliance responsibility remains with your institution while providing a framework for effective vendor management.