XYZ Bank
Customer Identification Program
Policy
Be it resolved, that it is the policy of
XYZ Bank________ to maintain maximum compliance
with the Customer Identification Program pursuant to Section 326 of the USA Patriot Act. The Board
of Directors appoints_____________________, (Title) as the officer to oversee the Customer
Identification Program of the Bank.
This policy shall apply to all persons who become customers of XYZ Bank after the date of the
adoption of this policy, which is (date). Persons who have previously had a relationship with XYZ
Bank will not be subject to the requirements of this policy providing we are reasonably assured we
know the true identity of the customer.
It is the Policy of XYZ Bank to obtain identifying information about every customer. If the customer
is an individual the bank will obtain the following:
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Individual’s name
Individual’s date of birth
Individual’s residence address (physical address)
If the individual is a U.S. person, the individual’s social security number. If the individual is a
non-U.S. person at least one of the following: U.S. taxpayer identification number; a passport
number and country of issuance; an alien identification card number and country of issuance or
any other government-issued document evidencing nationality or residence and bearing a
photograph or similar safeguard.
If the customer is not an individual, the bank will obtain the following:
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Customer’s name
Address of the customer’s principal place of business, local office or other physical location.
If the customer is a U.S. person, an employer identification number or if the person does not
have or is not required to apply for an employer identification number, the social security
numbers of the principals or the person. If the customer is a non-U.S. person, a U.S. taxpayer
identification number or if the customer is not required to have a U.S. taxpayer identification
number, a taxpayer identification number issued by the country of the customer’s residence.
It is the policy of XYZ Bank that it will not establish an account relationship with an individual until
the required information about the individual is obtained. If the person is a newly formed legal entity
and does not have a taxpayer identification number, but provides evidence that a taxpayer
identification number has been applied for then the account may be opened. In such case, the customer
will be required to provide its taxpayer identification number within eight weeks of the date that the
account is opened. If the taxpayer identification number is not so provided, the account shall be
closed.
It is the policy of XYZ Bank to verify the identity of every customer at the time of application and
prior to opening the account. XYZ Bank shall adopt procedures for verifying the identity of its
customers that are sufficient to enable the bank to form a reasonable belief that it knows the true
identity of the customer. The procedures shall be based on the risk presented by the various products
and services that XYZ Bank offers, the nature of the customer whose identity is being verified and the
business relationship with XYZ Bank that the customer is seeking.
Independent testing for compliance to the requirements of the Customer Identification Program will be
completed annually.
Training will be provided to appropriate personnel.
It is the policy of XYZ Bank to adhere to the following recordkeeping requirements:
1) All identifying information (name, date of birth, address, tax identification number) must be
maintained for 5 years after the account is closed. This information could be stored
electronically.
2) The following must be retained for five years after the record is created:
a. A description of the type of any document relied on for verification (driver’s license,
passport, etc.) including:
• the identification number on the document;
• place of issuance (country, state, etc.);
• date issued (if applicable);
• expiration date
b. A description of any non-documentary methods used and the result (credit report,
contacting customer, etc.);
c. Description of how any substantial discrepancies were resolved
It is the policy of XYZ Bank to provide customers with adequate notice that we are requesting
information to verify their identities. This notice can be given orally before opening the account or in
a manner reasonably designed to ensure that the customer is able to view the notice.
It is the policy of XYZ Bank to determine whether the customer appears on any list of known or
suspected terrorists or terrorist organizations within a reasonable period of time after the account is
opened, or earlier, if required by another Federal law or regulation.