Trust Tool- Individual Customer – CIP Verification and Risk Profile Checklist
Updated 10/20/2026
This template is intended to assist in identifying key individual customer information required for the Customer Identification Program (CIP). It can be tailored or adjusted to align with the specific requirements of the bank’s Trust Department BSA/AML Program.
Rule: FinCEN BSA/AML Manual/Customer Identification Program (CIP); Customer Identification Program Requirements for Banks (31 CFR 1020.220)
Toolkit: Trust
Keywords: Trust Account, Individual Customer Verification, Customer Identification Program (CIP), Trust Tool – Individual Customer – CIP Verification Checklist and Risk Profile
10/20/2026 – Moderate content and formatting revisions made to improve clarity.
6/12/2026 – 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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