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#2240098 - 07/24/20 03:27 PM CIP - Existing customers
Jennifer Offline
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Jennifer
Joined: Dec 2014
Posts: 190
Does the CIP regulation require banks to perform CIP on existing customers (opening new accounts) or only new customers?
Last edited by John Burnett; 07/27/20 05:54 PM. Reason: spelling in title of post
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BSA/AML/CIP/OFAC Forum
#2240103 - 07/24/20 03:49 PM Re: CIP - Existing customers Jennifer
ColoradoAML Offline
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Joined: Mar 2018
Posts: 338
No, CIP is not required for existing customers. If you are not applying CIP to existing customers, examiners will probably ask you for written explanation/justification. From regulation:

(2) Customer does not include:

(iii) A person that has an existing account with the bank, provided that the bank has a reasonable belief that it knows the true identity of the person.
Last edited by ColoradoAML; 07/24/20 03:49 PM.
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#2240105 - 07/24/20 04:02 PM Re: CIP - Existing customers Jennifer
Dan Persfull Offline
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Dan Persfull
Joined: Aug 2002
Posts: 47,517
Bloomington, IN
Here's a previous discussion. It comes down to what is required by your current CIP program.

https://www.bankersonline.com/forum/ubbthreads.php/topics/2144700/2
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The opinions expressed are mine and they are not to be taken as legal advice.

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