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Subject: Bank Secrecy Act/ Anti-Money Laundering
Date: April 28, 2005
To: Chief Executive Officers and Compliance Officers of All National Banks, Federal Branches and Agencies, Department and Division Heads, and All Examining Personnel
Description: Frequently Asked Questions (updated): Final Customer Identification Program Rule
The guidance attached to this bulletin continues to apply to federal savings associations.
On May 9, 2003, the Office of the Comptroller of the Currency (OCC) together with the Federal Reserve Board, Federal Deposit Insurance Corporation, Financial Crimes Enforcement Network, Office of Thrift Supervision, National Credit Union Administration, and the Treasury Department published a joint final rule, 31 CFR 103.121, titled "Customer Identification Programs for Banks, Savings Associations, Credit Unions and Certain Non-Federally Regulated Banks," at 68 FR 25090. The final rule implemented section 326 of the USA PATRIOT Act of 2001 and requires banks, savings associations, credit unions, and certain non-federally regulated banks to have a customer identification program (CIP).
On January 8, 2004, the OCC issued OCC Bulletin 2004-3 announcing that the agencies were publishing frequently asked questions (FAQs) to provide staff guidance on the application of the CIP rule.
This bulletin replaces OCC Bulletin 2004-3 and transmits updated FAQs jointly issued by the agencies that include additional staff guidance on the rule. Each FAQ is dated so that readers can identify the FAQs that have been added.
Questions on the FAQs may be directed to your OCC supervisory office or the Compliance Policy Department at (202) 874-4428.
Ann F. Jaedicke