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USA Patriot Act- CIP Notices

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We provide services non-account holders, as well as account holders. Our platforms require the creation of customer "folders" for all teller transactions. This means we capture CIP elements to create non-account holder folders to process those transactions. As the USA PATRIOT Act requires the capturing of CIP elements for account opening only (as far as I understand), are we also required to post customer CIP notices at the teller stations as well for non-account holders? Logic would dictate that the answer is yes, because the same CIP information is being collected for both groups, and we practice our KYC and AML principles for both. (Non-account holders or "consumers" can launder money or finance terrorism just as easily, or more easily, as an account holder.) However, the PATRIOT Act only requires the notices for account opening activities/locations. Technicality, I'm sure. But what is the right thing to do?

Whatever information you choose to gather from non-customers before performing one-time transactions at the teller window is solely a matter of bank policy and has nothing to do with CIP.

First published on 05/09/2021

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