Trust Tool – Trust and Asset Management BSA/AML Customer Identification Program Guidelines
Updated 04/23/2026
This tool is a general overview of the Trust and Asset Management BSA/AML Customer Identification Program and can be customized by the bank based on its unique organizational structure and risk profile. 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
Keywords: Trust Account, Asset Management BSA/AML CIP Guidelines, Trust and Asset Management, Trust and Wealth Management Services, Trust and Asset Management BSA/AML Customer Identification Program (CIP) Guidelines
4/23/2026 – Clarified citations and CIP address and identification number information, and added reference to interagency CIP exemption for collection of TIN and Trust and Asset Management Accounts section.
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