Question of the Week

Posted: Sep 16, 2021 | Author: Cornerstone League

BSA CIP

Question: Do we have to CIP another credit union or bank that wants to open an account?

Answer: No. The Bank Secrecy Act excludes certain persons from CIP coverage:

(2) Customer does not include:

(i) A financial institution regulated by a Federal functional regulator or a bank regulated by a State bank regulator;(ii) A person described in § 1020.315(b)(2) through (b)(4); or
(iii) A person that has an existing account with the bank, provided that the bank has a reasonable belief that it knows the true identity of the person.

This coverage excludes another financial institution regulated by a federal functional regulator (another credit union) or bank.

However, exclusion from CIP does not exclude from OFAC coverage. You should OFAC any person you do business with, consistent with your OFAC screening parameters.