Cip Policy

Draft Exam-Ready CIP Policies in Minutes, Not Hours

12 minutes with CaseMark

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12 minutes with CaseMark

What you'll need

Institution Profile & Risk Assessment
Existing AML/BSA Program Documents
Onboarding Procedures

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 fully structured policies covering identity collection, verification methods, OFAC screening, beneficial ownership, recordkeeping, and governance—tailored to your institution's specific charter type, risk profile, and product offerings.

Drafting and maintaining a compliant CIP policy is a labor-intensive process that requires deep knowledge of federal banking regulations, careful cross-referencing with existing BSA/AML programs, and meticulous attention to examination standards. Compliance teams often spend days or weeks researching requirements, structuring policy sections, and ensuring every regulatory citation is accurate—only to repeat the process when regulations change or examiners identify gaps.

CaseMark automates the heavy lifting of CIP policy creation by analyzing your institution's profile, existing compliance documents, and onboarding workflows to produce a comprehensive, properly cited policy draft in minutes. The AI ensures all required elements under Section 326 are addressed, flags areas needing human verification, and delivers a structured document ready for BSA Officer review and board approval.

How it works

1. Upload your institution profile, existing AML/BSA program documents, and onboarding procedures
2. AI analyzes your inputs and drafts a comprehensive CIP policy aligned with Section 326 and 31 CFR 1020.220
3. Review the generated policy, verify flagged citations, and customize institution-specific details
4. Export the exam-ready policy in your preferred format (DOCX, PDF) for BSA Officer and board approval

What you get

Policy Header and Version Control
Purpose, Authority, and Regulatory Citations
Scope, Definitions, and Account Taxonomy
Minimum Information Collection Requirements
Verification Methods and Procedures
OFAC Screening and Sanctions Protocols
CDD and Beneficial Ownership Requirements
Recordkeeping and Retention Schedules
Governance, Training, and Board Oversight

What it handles

Comprehensive Section 326 policy drafting with proper regulatory citations
Identity collection and verification method tables pre-populated by institution type
OFAC screening and CDD/beneficial ownership integration
Recordkeeping and retention schedules aligned with federal requirements
Governance framework with BSA Officer and board approval workflows
Automatic flagging of uncertain citations with [VERIFY] tags for review

Required documents

Institution Profile & Risk Assessment
Details about 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 filing procedures, and sanctions screening protocols
.pdf, .docx
Onboarding Procedures
Current customer onboarding workflows, system capabilities, and account opening procedures
.pdf, .docx

Supporting documents

Current CIP Policy
Existing CIP policy to be updated or used as a baseline for the new draft
.pdf, .docx
Examination Findings or MRAs
Recent regulatory examination findings, matters requiring attention, or audit reports related to CIP compliance
.pdf, .docx
Account Taxonomy Documentation
Definitions of account types, product coverage matrices, and customer classification schemas
.pdf, .docx

Why teams use it

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

Ensure regulatory compliance with accurate Section 326 and 31 CFR 1020.220 citations and requirements

Produce examination-ready documentation with proper structure, tables, and governance frameworks

Maintain consistency across your BSA/AML program with integrated cross-references to CDD, SAR, and sanctions policies

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, documentary and non-documentary verification, OFAC screening, CDD/beneficial ownership, and recordkeeping obligations.

Is the generated policy ready for regulatory examination?

CaseMark produces exam-ready drafts that include proper regulatory citations, required data collection tables, and governance frameworks. The AI flags uncertain citations with [VERIFY] tags so your compliance team can confirm accuracy before final approval.

Can it handle different institution types and charter structures?

Yes. CaseMark tailors the CIP policy based on your institution's charter type, product offerings, delivery channels, geographic footprint, and risk profile. Whether you're a community bank, credit union, or larger financial institution, the output reflects your specific structure.

How does it integrate with our existing BSA/AML program?

CaseMark analyzes your existing AML/BSA program documents—including CDD/EDD policies, SAR procedures, and sanctions protocols—to ensure the CIP policy is consistent and properly cross-referenced with your broader compliance framework.

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

CaseMark typically generates a comprehensive, multi-section CIP policy in approximately 10-15 minutes. This replaces what traditionally takes compliance teams days or weeks of manual drafting and research.

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

Absolutely. You can upload your current CIP policy alongside your institution profile, and CaseMark will identify gaps, update regulatory citations, and produce a revised policy that meets current examination standards.