Contact
← All workflows

Customer Identification Program (CIP) Policy

Generate Compliant CIP Policies in Minutes

15 minutes with CaseMark

Fast lane

We have it from here.

Choose the fast one-off run here, or jump into the workspace when you want saved history, revisions, and a fuller matter workflow.

Run this once here

Best for a quick one-off job. Add your email, upload the files, and we'll run the workflow and send the result to your inbox.

1. Add your email so we know where to send the result.

2. Upload the files you want analyzed.

3. Run the workflow and we'll take it from there.

Use in Workspace

Best for ongoing matters

Save and reopen matters, keep documents together, refine the output, rerun with changes, and export or share polished work product when you're done.

Open in Workspace

Need more context?

Scroll for the workflow details below if you want to review what this run handles, what documents help, and what the output looks like.

If this is part of a live matter, the workspace is the better fit: you can keep your documents together, revisit the result, and keep working without starting from scratch.

Jump to detailsOpen in Workspace

Start here

Run this workflow now

Best for a fast one-off run. Add your email, upload the files, and we'll deliver the result without sending you into the full app.

Workflow

Customer Identification Program (CIP) Policy

Step 1 · Deliver to

Step 3 · Run this workflow

Workflow

Customer Identification Program (CIP) Policy

Overview

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.

How it works

  1. 1. Upload your documents

  2. 2. AI analyzes and extracts key information

  3. 3. Review and customize the generated content

  4. 4. Export in your preferred format (DOCX, PDF)

What you get

  • Policy Overview and Purpose

  • Identification Procedures

  • Required Customer Information

  • Verification Methods

  • Recordkeeping Requirements

  • Customer Notice Provisions

  • Government List Comparison Procedures

What it handles

  • Policy Overview and Purpose

  • Identification Procedures

  • Required Customer Information

  • Verification Methods

  • Recordkeeping Requirements

  • Customer Notice Provisions

  • Government List Comparison Procedures

Required documents

  • Institution Profile

    Basic information about your financial institution including type, size, products offered, and customer base characteristics

    .pdf, .docx, .txt

Supporting documents

  • Existing CIP Policy

    Current Customer Identification Program policy for updating or revision

    .pdf, .docx

  • Examination Reports

    Recent regulatory examination findings related to CIP or BSA/AML compliance

    .pdf, .docx

  • BSA/AML Program Documentation

    Related compliance policies including beneficial ownership, enhanced due diligence, or SAR procedures

    .pdf, .docx

  • Risk Assessment

    Institution's BSA/AML risk assessment identifying customer, product, and geographic risks

    .pdf, .docx, .xlsx

Why teams use it

Generate complete CIP policies in 8 minutes vs. 3.5+ hours manually

Ensure USA PATRIOT Act compliance with built-in regulatory requirements

Include all mandatory elements: verification methods, recordkeeping, OFAC screening

Customize policies for banks, credit unions, and other financial institutions

Maintain consistent compliance documentation across your organization

Questions

What regulatory requirements does this CIP policy template cover?

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.

Can I customize the CIP policy for my specific type of financial institution?

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.

How does this ensure my CIP policy will pass regulatory examination?

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.

What's included for identity verification methods and procedures?

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.

Does the policy address third-party reliance and vendor management?

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.

Related

510k Premarket Notification

Draft FDA 510(k) Submissions in Minutes, Not Hours

Adverse Event Reporting Policy

Draft FDA-Compliant Adverse Event Policies in Minutes

Anti-Money Laundering (AML) Compliance Program

Draft AML Compliance Programs in Minutes, Not Days