I know this should be easy to find, but . . .

Since CIP is now part of 31CFR103 - I looked there first for the applicable fines and penalty limits. But 31 CFR 103 does NOT contain the usual section for "Enforcement, fines and penalties".

I then looked at the Bank Secrecy Act itself. Section 1955 says Civil Penalties for willful and gross negligence can be up to $10,000 and section 1956 says Criminal Penalties for willful violations can be up to $1,000 and/or imprisonment not more than a year.

Our Internal Audit Dept. is citing CIP fines under USA Patriot Act as min. of $10,000 and max. of $1,000,000. Where can I find if these amounts are correct now that CIP is a part of 31 CFR 103? Thanks.