Does anyone have (or know of) any CIP risk analysis models they'd be willing to share?? We are trying to figure out the best place to start.

I would love to have one also. Can anyone help?

Same song, different verse. I'd be ever so grateful for a risk analysis model for CIP if someone is willing to share.

The closest I could come up with is from the OTS. It's "USA PATRIOT Act Preparedness Check-Up". They give a checklist/questionnaire to assist in analyzing your current BSA/AML program, then developing, appling and testing the new program.

http://www.ots.treas.gov/docs/48931.pdf

I'll try to give you mine in a nutshell. (As it turns out, a very large nutshell.)

We have a separate excel spreadsheet for each of the following account types:

- personal deposit accounts
- business deposit accounts
- consumer loans
- mortgage loans
- commercial loans

Along the top of each spreadsheet are the following columns:
- risk factor
- possible characteristics
- Adds risk?
- Rate risk
- Adjustment to procedure to mitigate risk

The first 2 columns show the risk factor and the possible characteristics. For example, one risk factor is the method of account opening. The possible characteristics are: opened in person, joint account holder not present, opened without any account holders appearing in person.

The next column indicates whether or not that characteristic adds risk. Continuing the above example, an account opened in person does not add risk, one opened with a joint account owner not present, and one where no account holders appear in person do add risk.

The next column is to rate the risk. We have chosen the following risk ratings:
minimal - Characteristic adds minimal risk
moderate - Characteristic adds moderate risk
significant - Characteristic adds significant risk
unacceptable - Characteristic adds unacceptable level of risk

Again continuing my example, an account opened with a joint account owner not present could be said to add a moderate level of risk. One where no account holders appear in person adds a significant level of risk.

The final column indicates what additional procedures we will do to mitigate the increased risk. In my example, for a joint account owner not present, you might require signature of the joint owner to be notarized.

Here are our risk factors. I didn't give you the possible characteristics for things that would be bank specific, but hopefully, you'll get the idea.

Personal Deposit Account Risk Factors:
1.Method of Opening
- Opened in person
- Joint account holder(s) not present
- Opened without any account holders appearing in person
2.US/Non-US Person & Tax ID Number
- US Person with a Tax ID Number
- US Person who has applied for a Tax ID
- US Person with no Tax ID
- Non US Person with a Tax ID Number
- Non US Person who has applied for a Tax ID
- Non US Person without a Tax ID
3.Type of Identity Documents Presented
- Familiar ID (State issued driver's license, ID, US Passport)
- Unfamiliar ID
- No standard ID available (e.g., elderly/disabled)

Business Deposit Account Risk Factors
1.Type of Business Entity (for example, corporation, sole proprietorship, trust, etc.)
2.Type of Business (High risk or not high risk)
3.Method of Opening
- All signers in person
- One account signer present
- Opened without any account signers appearing in person
4.US/Non-US Person & Tax ID Number
- US Person with a Tax ID Number
- US Person who has applied for a Tax ID
- US Person with no Tax ID
- Non US Person with a Tax ID Number
- Non US Person who has applied for a Tax ID
- Non US Person without a Tax ID
5.Type of Identity Documents Presented
- Familiar ID
- Unfamiliar ID
- No documentary ID available

Mortgage Loan Risk Factors:
1.Method of Opening
- Appears in person at bank
- Appears in person at title company
2.US/Non-US Person & Tax ID Number
- US Person with a Tax ID Number
- US Person who has applied for a Tax ID
- US Person with no Tax ID
- Non US Person with a Tax ID Number
- Non US Person who has applied for a Tax ID
- Non US Person without a Tax ID
3.Type of ID documents presented
- Familiar ID
- Unfamiliar ID
- No standard ID available (e.g., elderly/disabled)

Consumer Loan Risk Factors:
1.Type of Loan
2.Type of collateral
3.Method of Opening
- Appears in person at bank
- Appears in person at title company
4.US/Non-US Person & Tax ID Number
- US Person with a Tax ID Number
- US Person who has applied for a Tax ID
- US Person with no Tax ID
- Non US Person with a Tax ID Number
- Non US Person who has applied for a Tax ID
- Non US Person without a Tax ID
5.Type of ID documents presented
- Familiar ID
- Unfamiliar ID
- No standard ID available (e.g., elderly/disabled)

Commercial Loan Risk Factors
1.Type of Loan
2.Type of borrower (for example, individual, corporation, trust, etc.)
3.Loan Purpose
4.Type of business (high risk or not high risk)
5.Type of collateral
6.Method of Opening
- Signers appears in person at bank
- Signers appears in person at title company
7.US/Non-US Person & Tax ID Number
- US Person with a Tax ID Number
- US Person who has applied for a Tax ID
- US Person with no Tax ID
- Non US Person with a Tax ID Number
- Non US Person who has applied for a Tax ID
- Non US Person without a Tax ID
8.Type of ID documents presented
- Familiar ID (Articles of incorporation, trust agreement, business license, etc. )
- Unfamiliar ID
- No documentary ID


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Me only, not my employer