USA PATRIOT Act: FinCEN Announces CIP Delay

FinCEN has announced a significant delay to the customer identification rules. It has also announced that compliance will not be required until long after the final rules are issued.

On the one hand, this is good news - or at least a relief. We won't be dragging the board through new policies at the eleventh hour or even just before the holiday festivities. Instead, we have some breathing room.

But the primary issue remains. Financial institutions should take great care to avoid conducting transactions, whether loan or deposit transactions, for individuals with criminal intentions. The breathing room provides the opportunity to do more work determining what we do know about customers, how we know it, and what we should know. Conduct this research now, and beginning in January, you can begin building or rebuilding an effective program.

Copyright © 2002 Compliance Action. Originally appeared in Compliance Action, Vol. 7, No. 13, 11/02