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#2151220 - 10/26/17 01:32 PM Existing customer and address change
Rae Offline
100 Club
Rae
Joined: Nov 2003
Posts: 192
Existing customer requests that we update his address to a P.O. box located in a different city within the same state. However he does not want to give us his new physical address. Is this a CIP issue? Accounts been opened for a while and we are comfortable since he passed CIP at account opening and we have not seen anything out of the ordinary with his activity.

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BSA/AML/CIP/OFAC Forum
#2151223 - 10/26/17 01:46 PM Re: Existing customer and address change Rae
McFly Offline
Member
Joined: Nov 2016
Posts: 75
Yes - need physical address for CIP. Updated P.O. Box is not enough.

You are responsible for updating if customer changes physical address.

Don't take no for an answer.
_________________________
CRCM, CAMS

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#2151226 - 10/26/17 01:49 PM Re: Existing customer and address change Rae
Daisy Doodle Offline
Diamond Poster
Joined: Feb 2014
Posts: 1,030
Southern U.S.
Not only CIP issue, but also fraud issue (if he commits any fraud against the bank) or CTR or SAR issue. I would not allow this.

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#2151227 - 10/26/17 01:49 PM Re: Existing customer and address change Rae
SeekingKnowledge Offline
100 Club
SeekingKnowledge
Joined: Jun 2014
Posts: 152
SC
This topic was discussed by some of the gurus in this thread a while back, you may find it helpful.

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#2151278 - 10/26/17 04:37 PM Re: Existing customer and address change Rae
JacF Offline

Power Poster
Joined: Nov 2001
Posts: 6,719
PA
CIP is applied at account opening, not in conjunction with ongoing maintenance. So this is not a CIP issue.

That said, there is plenty of good analysis in the thread linked by SeekingKnoweldge above.

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