Are we required to obtain a CIP, OFAC etc.. on a checking for an insurance agency we are purchasing which will be wholly owned subsidiary of our bank?
I was told after the account was opened that the CSR did not perform a CIP that the President told her it was not necessary. I know that you do not have to perform a CIP if you are a bank regulated by a federal or state regulator.

A subsidiary has its own legal identity. Unless it can be exempted on its own merits, it should be treated for CIP purposes as any other customer of the bank when it establishes an account. It does not enjoy the exemption from CIP requirements that its parent bank does when opening accounts.

On balance, the CIP ought to be pretty perfunctory. But it should be done.