Customer Identification Program (CIP)
Customer Identification Program (CIP) is the set of required procedures banks and credit unions use to verify the identity of customers at account opening. As a foundational component of BSA/AML compliance, CIP ensures the institution knows who it is doing business with before establishing a formal customer relationship.
For banks and credit unions, CIP:
- Applies at account opening, requiring identity verification before a customer relationship is established
- Defines minimum identifying information to be collected for individuals and entities, such as name, address, date of birth, and identification number
- Requires risk‑based identity verification, using documentary, non‑documentary, or combined methods
- Establishes procedures for resolving discrepancies, including situations where identity cannot be reasonably verified
- Mandates record retention, ensuring identification information and verification methods are documented and retrievable
- Requires customer notice, informing customers that identity verification is being performed as part of federal requirements
Across the financial institution, CIP serves as the entry point for customer risk management and downstream processes.
In deposits and payments, CIP determines whether accounts can be opened, funded, and transacted. In lending, it establishes borrower identity before underwriting, documentation, and funding activities begin. From a content and information management perspective, CIP drives the capture, storage, and governance of identity records that feed KYC, customer due diligence, audits, and examinations. As institutions modernize onboarding and account‑opening workflows, CIP increasingly relies on integrated digital tools that connect identity verification, document capture, and workflow controls—reducing friction while maintaining compliance consistency across channels and products.
