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Cip Policy

Draft Exam-Ready CIP Policies in Minutes, Not Hours

12 minutes with CaseMark

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Cip Policy

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Workflow

Cip Policy

Overview

CaseMark's CIP Policy Drafting skill uses AI to generate comprehensive, exam-ready Customer Identification Program policies compliant with USA PATRIOT Act Section 326 and 31 CFR 1020.220. The tool produces tailored policies covering identity collection, verification methods, OFAC screening, CDD/beneficial ownership, recordkeeping, and governance—all customized to your institution's specific risk profile and product offerings.

Drafting and maintaining a compliant CIP policy is a labor-intensive process that requires deep knowledge of BSA/AML regulations, careful alignment with institutional risk profiles, and meticulous attention to evolving regulatory expectations. Compliance teams often spend weeks assembling policy language, verification matrices, and governance frameworks—only to face gaps flagged during examinations.

CaseMark automates the heavy lifting of CIP policy drafting by analyzing your institution's profile, risk assessment, and existing AML/BSA program to generate a comprehensive, exam-ready policy document. The AI ensures proper regulatory citations, complete coverage of all required policy sections, and institution-specific customization—delivering in minutes what traditionally takes weeks of manual effort.

How it works

  1. 1. Upload your institution profile, risk assessment, and existing AML/BSA program documents

  2. 2. AI analyzes your institution's charter type, products, channels, and risk profile to draft a tailored CIP policy

  3. 3. Review the comprehensive policy with regulatory citations and verification tables

  4. 4. Export the exam-ready document in your preferred format (DOCX, PDF)

What you get

  • Policy Header and Approving Authority

  • Purpose, Authority, and Regulatory Citations

  • Scope, Definitions, and Account Taxonomy

  • Minimum Information Collection Requirements

  • Verification Methods and Procedures

  • OFAC Screening and Sanctions Procedures

  • CDD and Beneficial Ownership Requirements

  • Recordkeeping and Retention Schedule

  • Governance, Training, and Board Oversight

What it handles

  • Comprehensive Section 326 policy drafting with proper regulatory citations

  • Identity collection and verification method matrices for all customer types

  • OFAC screening and CDD/beneficial ownership procedures

  • Recordkeeping and retention schedules aligned with federal requirements

  • Governance framework with board approval and BSA Officer oversight

  • Exam-ready formatting with tagged items for regulatory verification

Required documents

  • Institution Profile & Risk Assessment

    Your institution's charter type, product offerings, delivery channels, geographic footprint, and BSA/AML risk assessment

    .pdf, .docx

  • Existing AML/BSA Program Documents

    Current BSA/AML policies including CDD/EDD, SAR, sanctions, and any existing CIP documentation

    .pdf, .docx

Supporting documents

  • Account Taxonomy & Product Definitions

    Definitions of account types, product coverage, and customer categories used by your institution

    .pdf, .docx, .xlsx

  • Current Onboarding Procedures

    Existing customer onboarding workflows, system capabilities, and identity verification procedures

    .pdf, .docx

Why teams use it

Reduce CIP policy drafting time from weeks to minutes with AI-powered document generation

Ensure regulatory alignment with Section 326, 31 CFR 1020.220, and related BSA/AML requirements

Produce exam-ready documentation with proper citations, structured tables, and verification matrices

Maintain consistency across your BSA/AML program with integrated CDD, OFAC, and beneficial ownership procedures

Questions

Does the CIP policy cover both documentary and non-documentary verification?

Yes. CaseMark generates detailed verification matrices covering documentary methods (government-issued IDs, formation documents) and non-documentary methods (database checks, consumer reports) with clear guidance on when each applies and what records to retain.

Will the policy be compliant with current Section 326 and 31 CFR 1020.220 requirements?

CaseMark drafts policies aligned with USA PATRIOT Act Section 326 and 31 CFR 1020.220. Uncertain or evolving regulatory citations are flagged with a [VERIFY] tag so your compliance team can confirm accuracy before finalization.

Can I customize the policy for my institution's specific products and channels?

Absolutely. CaseMark tailors the CIP policy to your institution's charter type, product offerings, delivery channels, geographic footprint, and risk profile. The output reflects your specific account taxonomy and onboarding workflows.

Does the output include OFAC screening and beneficial ownership procedures?

Yes. The generated policy includes dedicated sections for OFAC/sanctions screening procedures and CDD/beneficial ownership requirements, ensuring your CIP policy integrates seamlessly with your broader BSA/AML program.

How does this help with regulatory examinations?

CaseMark produces exam-ready documentation with proper regulatory citations, structured policy sections, and detailed procedure tables that examiners expect to see. This significantly reduces preparation time for BSA/AML examinations.

Can I update an existing CIP policy rather than drafting from scratch?

Yes. You can upload your current CIP policy alongside your institution profile, and CaseMark will identify gaps, update regulatory references, and produce a modernized version that meets current compliance standards.

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