Design a Customer Identification Program (CIP) that meets the minimum requirements of 31 CFR 1020.220 for a bank account-opening flow

Steps

1. Collect the four required identifiers before opening the account: name, date of birth (individuals), address, and identification number (SSN/TIN for US persons; TIN, passport number and country, or other government ID for non-US persons) per 1020.220(a)(2)(i)(A)
2. Build risk-based verification procedures using documents (unexpired government-issued photo ID) and/or non-documentary methods (credit bureau, public database, reference checks) per 1020.220(a)(2)(ii)
3. Implement the taxpayer-identification-number exception: allow account opening before a TIN is received if the application was filed first, with procedures to obtain the TIN within a reasonable time afterward
4. Add procedures for 'lack of verification' outcomes: when not to open the account, what the customer may do while verification is pending, when to close the account, and when to file a SAR, per 1020.220(a)(2)(iii)
5. Record and retain all identifying information for five years after the account is closed, and retain verification-method records for five years after the record is made, per 1020.220(a)(3)
6. Provide customer notice describing the identification requirements before or at account opening per 1020.220(a)(5)