The Financial Crimes Enforcement Network (FinCEN) has released the Customer Identification Programme requirements proposed for US firms, under Section 326 of the *USA PATRIOT Act*. (see site link below)
It is proposed that firms follow “reasonable procedures” to ascertain the identities of people who want to open accounts, make sure that their records are properly kept, and compare their customers with names on government lists. According to FinCEN, AML programmes must include *”internal policies, procedures and controls to ensure ongoing compliance; the designation of a compliance officer; an ongoing employee training programme; and an independent audit function to test the programmes”.*
The introduction of CIPs applies to banks, savings associations, credit unions, futures commission merchants, introducing brokers, mutual funds, broker dealers, and federally unregulated firms, such as trust companies and private banks.
FinCEN is seeking industry feedback on the proposed rule, Section 326. Parties interested in contributing should e-mail FinCEN by 6 September 2002.