Mostly ignored and long forgotten:
(2) Identity verification procedures. The CIP must include risk-based procedures for verifying the identity of each customer to the extent reasonable and practicable. The procedures must enable the bank to form a reasonable belief that it knows the true identity of each customer. These procedures must be based on the bank's assessment of the relevant risks, including those presented by the various types of accounts maintained by the bank, the various methods of opening accounts provided by the bank, the various types of identifying information available, and the bank's size, location, and customer base. At a minimum, these procedures must contain the elements described in this paragraph (a)(2).
This is a good time for banks to formally update their CIP risk assessment (assuming they ever did one) and establish a CIP with specific requirements and, perhaps a beneficial owner identification program (BOIP) with lesser requirements.
Suggestion: If you combine the use of one piece of identification with nondocumentary verification, there is no need to get the second piece of ID for CIP purposes. For beneficial owners, a photocopy of identification is fine, just make sure you require something with at least 3 of the 4 markers; e.g. a drivers license, not a passport.
In this world you must be oh so smart or oh so pleasant. Well, for years I was smart. I recommend pleasant.