Answer:
Yes, actually the proper terminology would be that your CIP program must include a “risk based” approach when verifying the customer’s identity. This simply means that when opening new accounts, your institution is entitled to decide how much verification is required. There is very little guidance outlining how banks are suppose to develop this process and ultimately it has been left up to the individual institutions. Here is a link of a sample CIP Risk Analysis worksheet that might help you identify different levels of risk and create steps to address those risks.
First published on BankersOnline.com 4/18/05