Trust Tool- Customer Identification Program Matrix
Updated 07/22/2026
This tool is intended as a general Customer Identification Program (CIP) matrix. The bank should customize it to align with its specific risk profile, the products and services it offers, and its organizational structure. This document is not a substitute for official legal documentation.
Rule: FFIEC BSA/AML Assessing Compliance with BSA Regulatory Requirements – Customer Identification Program; 31 CFR 1020.220; FDIC FIL-26-2025; FFIEC BSA/AML Risks Associated with Money Laundering and Terrorist Financing – Trust and Asset Management Services
Toolkit: Trust
Keywords: Trust Account, BSA/AML Program, Customer Identification Program (CIP) Matrix, CIP Program
7/22/2026 – Moderate content and formatting revisions made to improve clarity.
Note: On May 19, 2026, President Trump issued Executive Order 14406, Restoring Integrity to America’s Financial System. Subsequently, FinCEN, jointly with the FDIC and OCC, issued Joint Advisory FIN-2026-A002 addressing BSA/AML risks associated with non-work-authorized populations, and the CFPB issued its Statement on Ability to Repay and Immigration Status regarding the consideration of immigration status and repayment risk in underwriting decisions. As of this writing, additional guidance regarding related credit-risk management expectations remains pending.
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