Enigma Knowledge

Glossary

CIP: Customer Identification Program

February 5, 2026

What Customer Identification Program means and how CIP requirements form the foundation of identity verification.

A Customer Identification Program (CIP) is a US regulatory requirement under the Bank Secrecy Act mandating financial institutions to verify the identity of individuals opening accounts.

CIP Requirements

Information Collection

  • Name
  • Date of birth
  • Address
  • Identification number (SSN for US persons; passport/other for non-US)

Verification Methods

  • Documentary: Government-issued ID review
  • Non-documentary: Database verification, credit bureau checks
  • Combination: Multiple methods for higher confidence

Additional Requirements

  • Check against government lists
  • Maintain records of verification procedures
  • Notify customers of identification requirements

CIP vs. CDD

Origin

  • CIP: USA PATRIOT Act Section 326 (2001)
  • CDD: FinCEN CDD Rule (2016)

Focus

  • CIP: Identity verification
  • CDD: Risk assessment

Beneficial Ownership

  • CIP: Not required
  • CDD: Required

Ongoing Monitoring

  • CIP: Not explicit
  • CDD: Explicit

CIP establishes the baseline; CDD builds on it with deeper understanding and risk assessment.

CIP for Business Accounts

For business accounts, CIP extends to:


Related: KYC | BSA | CDD