Not necessarily. The two requirements have obvious similarities, and FinCEN connects them by requiring similar identification verification steps. However, if Corporation A opened a checking account under full CIP procedures two years ago, it would not be a violation to skip the CIP process when it opens another checking account this week, since CIP is a customer-related requirement. But the beneficial ownership certification under CDD is required for each new account (account-related) despite the fact it gathers customer-related information. Omitting the CDD certification of beneficial ownership would be a violation, but it would not violate CIP rules.