From the BSA Manual:
Adequate Customer Notice
The CIP must include procedures for providing customers with adequate notice that the bank is requesting information to verify their identities. The notice must generally describe the bank's identification requirements and be provided in a manner that is reasonably designed to allow a customer to view it or otherwise receive the notice before the account is opened. Examples include posting the notice in the lobby, on a web site, or within loan application documents.
You should be fine as long as it is placed where the customer can see it. We have one 8 1/2" by 11" version in our lobbies with smaller versions at the new accounts desks, where the customers can view them during their account opening. We also printed it on our service charge brochure for an added measure. This has passed with our Auditors and Examiners with no problem.
I use to think I was a smart cookie before I started working in Compliance. Now, I have mastered the art of the blank stare!