CIP FAQs - Can a bank exclude from the definition of “customer” a person that has an existing account with its affiliate

Compliance > BSA > FinCEN FAQs - CIP
Q:  Can a bank exclude from the definition of “customer” a person that has an existing account with its affiliate?
 
A:  No, a person that has an existing account with a bank affiliate does not qualify as “a person who has an existing account with the bank” within the meaning of 31 C.F.R. § 103.121(a)(3)(ii)(C).  However, the bank may be able to rely on its affiliate to perform elements of its CIP, as provided in 31 C.F.R. § 103.121(b)(6).  (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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