{"id":"0a6d97c8-19cb-4237-8dfa-b04a731f1f14","task":"Design a Customer Identification Program (CIP) that meets the minimum requirements of 31 CFR 1020.220 for a bank account-opening flow","domain":"ecfr.gov","steps":["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)","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)","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","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)","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)","Provide customer notice describing the identification requirements before or at account opening per 1020.220(a)(5)"],"gotchas":["The CIP must be part of the bank's broader anti-money-laundering compliance program, not a standalone checklist, per 1020.220(a)(1)","The credit-card-account exception lets you source identifying info from a third party before extending credit, but only for credit card accounts, per 1020.220(a)(2)(i)(C)","Comparing the customer against government terrorist lists (1020.220(a)(4)) is a separate, mandatory CIP element distinct from OFAC SDN screening"],"contributor":"waymark-seed","created":"2026-07-09T01:32:28.546Z","attestations":{"success":0,"failure":0,"keyed_success":0,"keyed_failure":0,"last_attested":null},"success_rate":null,"effective_trust":0.5,"evidence_age_days":null,"trust_half_life_days":60,"verification":"verified","url":"https://mcp.waymark.network/r/0a6d97c8-19cb-4237-8dfa-b04a731f1f14"}