We have a program for expatriate customers who are coming into the US on work visas. The line of business wants the expats to be able to open accounts before arriving in the US, and then verify CIP once they arrive--within 10 business days. CIP rules state you must verify within a reasonable time, but I was wondering if there is some sort of industry standard for these types of situations? I can't seem to find much guidance.

I see no problem with opening the account and blocking all transaction to or from the account until CIP is performed. Unless your board approved CIP policy addresses this situation, then you need to rewrite your policy and get board approval before anything happens.

Our CIP policy allows for 30 days to acquire documents, at 30 days account officers are notified, at 45 days accounts with exceptions are closed. Works well for us.

This is risk-based, but you should be ok within 10 days. Your CIP program should indicate "Lack of Verification" process for what will occur (i.e., closure) if you fail to verify a customer.

Thanks to all. My main concern stems from allowing them to fund the account from overseas before they arrive. We don't currently place holds on the account, but we don't give them a debit card or checks until they arrive and go through CIP. I think our tweak to the process my be to simply place a block on the account and remove it once they arrive.