Cip Policy

Draft Exam-Ready CIP Policies in Minutes, Not Hours

12 minutes with CaseMark

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Upload your documents and get a finished work product in minutes. New accounts get $5 free to run their first skill.

12 minutes with CaseMark

What you'll need

Institution Profile & Risk Assessment
Existing AML/BSA Program Documents

SOC 2 Type II · HIPAA compliant · $5 free credit

Workflow

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 a fully structured policy covering identity collection, verification methods, OFAC screening, CDD/beneficial ownership, recordkeeping, and governance—tailored to your institution's specific profile and risk posture.

Drafting and updating CIP policies is a labor-intensive process that requires compliance teams to cross-reference multiple federal regulations, tailor requirements to the institution's products and risk profile, and produce documentation that satisfies both internal governance and regulatory examiners. Manual drafting often takes days, introduces inconsistencies, and risks gaps in regulatory coverage.

CaseMark automates CIP policy drafting by analyzing your institution profile and existing AML/BSA program to generate a comprehensive, regulation-aligned policy in minutes. The AI produces structured sections with populated tables, verification checklists, and flagged citations—delivering an exam-ready draft that your BSA Officer and board can review and approve with confidence.

How it works

1. Upload your institution profile, risk assessment, and existing AML/BSA program documents
2. AI analyzes your inputs and drafts a comprehensive CIP policy aligned with Section 326 and 31 CFR 1020.220
3. Review the structured policy with pre-populated tables, verification checklists, and flagged citations
4. Export the exam-ready policy in your preferred format (DOCX, PDF) for BSA Officer and board approval

What you get

Policy Header & Version Control
Purpose and Legal Authority
Scope, Definitions & Account Taxonomy
Minimum Information Collection Tables
Verification Methods & Checklists
OFAC Screening & Sanctions Procedures
CDD & Beneficial Ownership Requirements
Recordkeeping & Retention Schedule
Governance, Training & Board Oversight

What it handles

Generates complete CIP policy with all required sections including purpose, scope, definitions, and governance
Populates identity collection tables for individuals, entities, and non-U.S. customers
Covers documentary and non-documentary verification methods with checklists
Includes OFAC screening, CDD, and beneficial ownership procedures
Builds recordkeeping and retention schedules aligned with regulatory requirements
Tags uncertain citations as [VERIFY] for efficient BSA Officer review

Required documents

Institution Profile & Risk Assessment
Your institution's charter type, product offerings, delivery channels, geographic footprint, and enterprise-wide or BSA risk assessment
.pdf, .docx
Existing AML/BSA Program Documents
Current BSA/AML policies, CDD/EDD procedures, SAR filing protocols, sanctions screening procedures, and any prior CIP documentation
.pdf, .docx

Supporting documents

Account Taxonomy & Product Definitions
Definitions of covered accounts, product types, and any exclusions currently applied under your onboarding framework
.pdf, .docx, .xlsx
Current Onboarding Workflows
Documentation of existing customer onboarding procedures, system capabilities, and identity verification workflows
.pdf, .docx

Why teams use it

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

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

Produce consistent, structured policies with pre-populated tables and verification checklists

Streamline exam preparation with flagged citations and board-ready formatting

Questions

What regulations does the CIP policy cover?

CaseMark drafts policies fully aligned with USA PATRIOT Act Section 326 and 31 CFR 1020.220. The output covers all required elements including identity collection, verification, OFAC screening, CDD/beneficial ownership, recordkeeping, and governance.

Is the generated policy ready for a regulatory exam?

CaseMark produces an exam-ready draft that follows the structure and substance regulators expect. Any uncertain regulatory citations are flagged with [VERIFY] tags so your BSA Officer can confirm accuracy before final approval.

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

Absolutely. CaseMark uses your institution profile, account taxonomy, and existing workflows to tailor the policy to your charter type, product lines, delivery channels, and risk appetite.

How does CaseMark handle different customer types?

The generated policy includes separate identity collection and verification requirements for individuals, entities, and non-U.S. persons, each with appropriate data fields, documentary requirements, and risk-based procedures.

Does the policy include OFAC and beneficial ownership requirements?

Yes. CaseMark integrates OFAC screening procedures, Customer Due Diligence (CDD) requirements, and beneficial ownership identification into the policy as distinct, fully developed sections.

How long does it take to generate a complete CIP policy?

CaseMark typically generates a comprehensive, multi-section CIP policy in approximately 12 minutes. This replaces what traditionally takes compliance teams days or weeks of manual drafting and cross-referencing.