How do you handle CDD on CIP exempt cusotmers? If I am not required to even identify the new customer, why would I perform due diligence? Can I just indicate that the AML risk is so low (as demonstrated by the fact that I don't have to identiy the customer), that due diligence is not necessary?

Has this worked for anyone?

Context: I work for a bank subsidiary that offers only one type of product - time deposits. There is no reason to define expected transactional activity because there is no expected activity. Also, all of customers are in the same low-risk geographic area.


Thanks

I would be amazed if there was no CIP or CDD on any customers no matter what type of account they have.

As for my bank, we dont have any CIP exempt customers. Per our policy we CIP every business and every signer on an account, no matter what the line of business is.

There are different levels of due diligence that we perform and they are not just transactional.

"Exempt" may be a bit misleading; the CIP regulation does not use that word. The regulation simply excludes banks, government entities, and publicly traded companies listed on a major exchange from the definition of "customer."

As a matter of practicality, your due diligence on these customers would be limited.