Which is considered a minimum requirement in a customer identification program?

Account opening procedures that specify the information to be obtained from each customer is a fundamental minimum requirement of any Customer Identification Program. CIPs must establish clear procedures for collecting identifying information (name, date of birth, address, identification number) at account opening. This forms the foundation of the "know your customer" process and is explicitly mandated in regulations like the USA PATRIOT Act Section 326 and similar international standards. Without these procedures, financial institutions cannot verify customer identity or maintain required records.

A. Transaction reporting relates to Suspicious Activity Reports (SARs), not core CIP requirements.
B. Transaction monitoring is an AML compliance activity, not a CIP minimum requirement.
D. Enhanced due diligence applies to high-risk customers only, not a minimum CIP requirement.

1. USA PATRIOT Act Section 326 (31 U.S.C. 5318(l)) - Customer Identification Programs

2. 31 CFR 1020.220 - Customer identification program requirements for banks

3. FATF Recommendation 10 (Customer Due Diligence) - International Standards on Combating Money Laundering

4. Federal Financial Institutions Examination Council (FFIEC) BSA/AML Examination Manual, Customer Identification Program section

5. Wolfsberg Group Guidance on Customer Identification Program Requirements (2020)