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Cip Policy

Draft Exam-Ready CIP Policies in Minutes, Not Days

12 minutes with Para

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Get started with Para

Para is an AI colleague for legal teams. Send it this work by email, Teams or Slack, and it hands back the finished document.

12 minutes with Para

What you'll need

  • Institution Profile & Risk Assessment
  • AML/BSA Program Documents
  • Account Taxonomy & Onboarding Procedures

Plans from $20 a month, with usage included.

Workflow

Overview

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

Drafting and updating CIP policies is a painstaking process that requires deep familiarity with Section 326, FinCEN guidance, OFAC requirements, and evolving beneficial ownership rules. Compliance teams spend days cross-referencing regulations, adapting templates to their institution's products and channels, and ensuring no examiner-flagged gaps remain—only to repeat the process with every regulatory update.

CaseMark automates the heavy lifting of CIP policy drafting by analyzing your institution profile, existing AML/BSA program, and onboarding workflows to produce a comprehensive, structured policy in minutes. The AI covers every required section—from identity collection tables to governance frameworks—while flagging uncertain citations for human review, giving your compliance team an exam-ready starting point instead of a blank page.

How to hand this to Para

  1. 1. Send Para the files

    Email them, drop them in a Teams or Slack message, or upload them.

  2. 2. Para runs the Cip Policy skill

    It works from your files and checks its citations against the record.

  3. 3. The finished document comes back

    Para returns it where you asked, usually as a DOCX, and offers the next step.

Example request · email, Teams or Slack
Para, run the Cip Policy skill for the Garcia matter. I've attached the Institution Profile & Risk Assessment, AML/BSA Program Documents and Account Taxonomy & Onboarding Procedures. Send the finished draft back here as a DOCX.

What Para does

  1. 1. Upload your institution profile, existing AML/BSA program documents, and onboarding procedures
  2. 2. AI analyzes your inputs and drafts a comprehensive CIP policy across all required sections
  3. 3. Review the structured policy, verify flagged citations, and customize to your institution
  4. 4. Export the exam-ready policy in your preferred format (DOCX, PDF)

What you get

  • Policy Header & Version Control

  • Purpose, Authority & Regulatory Citations

  • Scope, Definitions & Account Coverage

  • Minimum Information Collection Requirements

  • Documentary & Non-Documentary Verification Methods

  • OFAC Screening & Sanctions Procedures

  • CDD & Beneficial Ownership Requirements

  • Recordkeeping & Retention Schedule

  • Governance, Training & Board Oversight

What it handles

  • Generates complete CIP policies aligned with Section 326 and 31 CFR 1020.220

  • Covers identity collection, documentary and non-documentary verification methods

  • Includes OFAC screening, CDD, and beneficial ownership requirements

  • Produces structured recordkeeping and retention schedules

  • Builds governance framework with board approval and audit provisions

  • Flags uncertain regulatory citations with verification markers

Required documents

  • Institution Profile & Risk Assessment

    Charter type, product offerings, channels, geographic footprint, and BSA/AML risk assessment

    .pdf, .docx

  • AML/BSA Program Documents

    Existing BSA/AML policies including CDD/EDD, SAR, and sanctions procedures

    .pdf, .docx

  • Account Taxonomy & Onboarding Procedures

    Definitions of covered accounts, product types, and current customer onboarding workflows

    .pdf, .docx

Supporting documents

  • Existing CIP Policy

    Current CIP policy to be updated or used as a baseline for revision

    .pdf, .docx

  • Examination Findings or Audit Reports

    Recent regulatory examination findings or internal audit reports related to CIP compliance

    .pdf, .docx

  • System Capabilities Documentation

    Documentation of core banking or onboarding system capabilities for identity verification

    .pdf, .docx

Why teams use it

Reduce CIP policy drafting time from days of manual work to minutes of AI-assisted generation

Ensure comprehensive coverage of all Section 326 requirements with structured, citation-backed sections

Eliminate gaps in OFAC screening, CDD, and beneficial ownership provisions that examiners commonly flag

Maintain consistent, institution-specific language across all policy sections with built-in version control

Questions

Does this CIP policy comply with current USA PATRIOT Act Section 326 requirements?

Yes. CaseMark drafts policies structured around Section 326 and 31 CFR 1020.220, covering all required elements including identity collection, verification, OFAC screening, and recordkeeping. Uncertain citations are flagged for your BSA Officer to verify before finalization.

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 offerings, digital and in-branch channels, and risk appetite. Every section is fully editable after generation.

Does the output include beneficial ownership and CDD requirements?

Yes. CaseMark integrates CDD and beneficial ownership provisions into the CIP policy, covering 25% ownership thresholds, control prong identification, and ongoing monitoring obligations consistent with FinCEN requirements.

Is the generated policy ready for regulatory examination?

CaseMark produces exam-ready drafts with proper regulatory citations, structured tables, and governance provisions. However, we recommend routing the final draft through your BSA Officer and legal counsel for institution-specific review before board approval.

How does CaseMark handle different customer types like entities and non-U.S. persons?

The AI generates differentiated requirements for individuals, entities, and non-U.S. persons, including specific identification documents, risk-based verification tiers, and enhanced due diligence triggers appropriate to each customer category.

Can I update an existing CIP policy instead of creating one from scratch?

Yes. Upload your current CIP policy along with your institution profile, and CaseMark will identify gaps, update regulatory citations, and produce a revised policy that addresses current requirements while preserving your existing institutional language where appropriate.

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