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#482631 - 01/12/06 09:27 PM CIP
#1hogfan Offline
100 Club
Joined: Mar 2005
Posts: 105
Arkansas
If we cash a savings bond for a non-customer, would we need to fill out a CIP form for them. I think no, but have had some differing opinions.

Thanks in advance.

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BSA/AML/CIP/OFAC Forum
#482632 - 01/12/06 09:48 PM Re: CIP
GuitarDude Offline
Power Poster
GuitarDude
Joined: Nov 2004
Posts: 5,925
So Cal
No. You just answered your own question with the term "non-customer."
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I've just writed a wrong.

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#482633 - 01/13/06 03:17 PM Re: CIP
ChristinaA Offline
Member
Joined: Nov 2005
Posts: 68
But wouldn't you have to run an OFAC check on the non-customer? We were told by our auditors that we have to peform an OFAC check on every non-customer transaction.

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#482634 - 01/13/06 03:40 PM Re: CIP
LauraL Offline
Gold Star
Joined: Jun 2005
Posts: 365
Georgia
Yes, you would have to run OFAC (depending on your risk assessment), but the person in this example is a non-customer, so CIP rules do not apply.

CIP and OFAC, two separate things.
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"I'd rather be running a marathon than doing compliance!"

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