one of our corporate accounts is leaving because we wanted the information on a new signer to the account. Would a new signer not be subject to our CIP? We were just wanting to make sure joe was actually joe.

The CIP regulations do not require CIP procedures to be performed on signatories of business accounts (signors only no account ownership) as long as you have CIP'd the business. Your bank policy however may state that you require signatories of business accounts to be put through your CIP procedures.

Per USA PATRIOT at a minimum you must obtain the name and identifying (for an individual the SSN) of the signatories - anything further would be per your finanacial insitutions Customer Identification Program.

While the proposed regulations required it, the final CIP regulations do not require the bank to ID mere signatories on corporate accounts. In my opinion a CIP policy to require identification of signatories whether they are added at account inception or some later time is a "best practice." (That observation reflects more concern for fraud prevention than AML.) If your CIP requires it, then you have no choice.

ooops - my bad - I guess we just went with the proposed rules to save ourselves stress with changing down the road!