{"id":34306,"date":"2026-06-29T17:43:40","date_gmt":"2026-06-29T17:43:40","guid":{"rendered":"https:\/\/www.complycube.com\/?p=34306"},"modified":"2026-06-26T14:49:17","modified_gmt":"2026-06-26T14:49:17","slug":"requisitos-de-cip","status":"publish","type":"post","link":"https:\/\/www.complycube.com\/es\/cip-requirements\/","title":{"rendered":"C\u00f3mo los requisitos de CIP afectan a los bancos estadounidenses"},"content":{"rendered":"
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TL;DR: <\/strong>Customer Identification Program requirements known as CIP requirements<\/strong> outline how U.S. banks must collect, verify, and keep<\/strong> customer data before starting a business relationship. Under U.S. Bank Secrecy Act (BSA), strong CIP includes identity data collection, customer verification, and recordkeeping. CIP compliance relies more on risk-based Identity Verification (IDV)<\/strong>.<\/p>\n<\/div>\n\n\n

The First Trust Decision in Banking<\/h2>\n\n\n\n

A customer opens a banking app and enters their name, date of birth, address, and identification number. Then, they tap submit to end their journey. For most customers, this is an everyday occurrence. However, for the bank, this is the first major risk decision in the onboarding process.\u00a0<\/p>\n\n\n\n

According to the 2026 National Money Laundering Risk Assessment from the United States Department of the Treasury, fraud and drug trafficking generated hundreds of billings of dollars in illicit proceeds each year. Moreover, cybercrime, human trafficking, and corruption generated billions more, making the stakes higher than ever.<\/p>\n\n\n\n

Often, a customer is genuine. In other instances, bad actors may be using stolen data, a synthetic identity. or a manipulated document. They can also use a mule account profile to move illicit funds from money laundering or terrorism financing. Unfortunately, at account opening, banks have no transaction history, long-term behavior pattern, or similar formal banking relationships to rely on. provided by:<\/p>\n\n\n\n

That is where a Customer Identification Program (CIP) begins. Beyond a compliance form, it is the point at which a bank decides whether identity evidence is strong enough. With the right information, bank accounts can be opened, applications can be escalated, or new accounts can be declined. You can learn more: Customer Identification Program: What is CIP?<\/a><\/p>\n\n\n\n

What are CIP Requirements?<\/h2>\n\n\n\n

CIP requirements are the legal and operational rules that require banks and other financial institutions to verify customer identities. This is a part of a wider Anti-Money Laundering (AML) compliance program that the bank establishes. Under 31 CFR 1020.220<\/a>, a bank must maintain an AML program. Banks must implement a written CIP as needed for the bank’s size and the type of business.<\/p>\n\n\n\n

CIP must not be treated as a formality. The data is only useful when it is verified. The process typically checks customer risk, the account type, as well as any additional evidence that is available at the time of onboarding.<\/p>\n\n\n\n

\"U.S.<\/figure>\n\n\n\n

The CIP Rule requires risk-based procedures for checking customer identity. They must allow banks to form a reasonable belief around the customer’s true identity. They do this through methods such as gathering identifying information, applying verification methods, and handling exceptions. Most banks collect information such as name, date of birth, address, and an identification number such as a taxpayer identification number, passport number, or details from another government-issued document.<\/p>\n\n\n\n

Evaluating Strong CIP Frameworks<\/h3>\n\n\n\n

A strong CIP framework is where customer experience, fraud prevention, and financial crime control first meet. This helps genuine customers move through onboarding while giving higher-risk applications the scrutiny they deserve. Banks must also retain CIP records. Banks must retain customer identifying information for five years after the account closes, while records showing the verification method, results, and supporting evidence are generally kept for five years from the date the record is created.<\/p>\n\n\n\n

The FFIEC BSA\/AML Examination Manual<\/a> frames CIP as an area examiners use to assess compliance with Bank Secrecy Act regulatory requirements. Banks need clear procedures that teams can follow, internal controls can test, and federal functional regulators can review and evidence. For example, in 2025, Hatch Bank<\/a> was required to review and revise due diligence procedures, including its Customer Identification Program.<\/p>\n\n\n\n

These minimum requirements should reflect the bank\u2019s size, customer base, accounts maintained, credit card accounts, products, account-opening methods, legal entities, and potential risks identified in the bank\u2019s risk assessment. The harder challenge is making that structure work where customers expect speed and fraudsters look for weak points.<\/p>\n\n\n\n

Why CIP Requirements Are Necessary For Financial Crime Prevention<\/h2>\n\n\n\n

Today, a bank’s front door could be virtually anything. For many customers, it could be a mobile app, an onboarding flow, or even an embedded finance journey. As a result, these onboarding methods can welcome a genuine customer or admit risky actors into the financial ecosystem.<\/p>\n\n\n\n

\"Triangle<\/figure>\n\n\n\n

The Bank Secrecy Act and USA PATRIOT Act framework made\u00a0customer identification<\/a>\u00a0an essential part of the fight against money laundering, terrorist organizations, and other financial criminal activity. Section 326 of the USA PATRIOT Act laid the foundation for today’s CIP regulations, asking financial institutions to implement thorough procedures for verifying customer identities.<\/p>\n\n\n\n

When a financial institution has a weak CIP, it can leave huge gaps in its controls. As a result, banks, credit unions, and other major financial institutions are more exposed to risks such as mule activity, fraud, and suspicious transactions. In practice, this creates a lot of downstream risk when clients try to move funds across products, channels or counter parties. This makes it harder to spot unusual behavior early.<\/p>\n\n\n\n

CIPs are now a front-door safeguard. They must balance speed, internal controls, and auditability in one account-opening journey. Though CIP is rooted in bank account opening, the regulatory direction is much broader. With digital payment models growing, customer identification expectations are moving into products and partnerships that look less like traditional bank accounts. They still carry a lot of financial crime risk.<\/p>\n\n\n

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Case Study: StableCoin CIP Proposal<\/strong><\/h3>\n

Today, payment stablecoins support fast digital financial transactions. That speed creates major exposure to money laundering, sanctions evasion, and terrorist financing when customer IDV is weak or inconsistent.<\/p>\n

Incorporating CIP Requirements<\/h3>\n

The Financial Crimes Enforcement Network (FinCEN), Federal Reserve, and FDIC as well as other regulatory bodies, proposed CIP requirements applying to payment stablecoin issuers<\/a> under the GENIUS Act. These new requirements states that issuers to maintain written, risk-based CIPs.<\/p>\n

Outcomes<\/h3>\n