CIP FAQs - Is the CIP rule applicable to a bank’s foreign subsidiaries?

Compliance > BSA > FinCEN FAQs - CIP
Q:  Is the CIP rule applicable to a bank’s foreign subsidiaries?
 
A:  No.  The CIP rule does not apply to any part of the bank located outside of the United States.  Nevertheless, as a matter of safety and soundness, banks are encouraged to implement an effective CIP throughout their operations, including in their foreign offices, except to the extent that the requirements of the rule would conflict with local law.  (January 2004)
 

ADDITIONAL INFORMATION
This FAQ was excerpted from the Interagency Interpretive Guidance on CIP Requirements that can be found at the following link:  https://www.fincen.gov/sites/default/files/guidance/faqsfinalciprule.pdf
 

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