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.