We are in process of opening an account for a court-appointed receiver and having a bit of a debate over who the customer is for CIP. The receivership itself does have an EIN - are they the "customer" for CIP purposes?

You are opening a deposit account for a receiver? Or is it a loan with a receiver? Usually the receiver manages the account(s) for the court. We still recognize the customer.

when the receiver closes the account(s), we CIP him/her at that point with the court document with the instructions.

It's a deposit account; looks to me like the receiver is basically going to be running the business entity in question and this account is for that purpose. I have the court order, a EIN for the receivership, a physical address. Is that enough for CIP or do I need to have the officer complete CIP for the signer/receiver?