Identity verification
Include fields to record the specific ID used, issuing authority, expiration, and the verification method (document review, database match, or third-party service) to evidence CIP steps.
Completing this form documents lawful identity verification, reduces regulatory risk, and creates an auditable trail for examiners and internal compliance. It supports compliance with 31 U.S.C. §5318(l) (PATRIOT Act CIP obligations), FinCEN implementing regulations, and fits electronic recordkeeping when executed under ESIGN (15 U.S.C. §7001) or state UETA provisions.
The Legal Patriot Act Information Form is used by institutions subject to BSA/CIP rules and by individuals or entities when opening regulated accounts or transacting with regulated providers.
Use of the form helps institutions demonstrate consistent procedures across customer intake, onboarding, and periodic review processes.
A designated compliance or AML officer oversees form design, verifies CIP practice, documents verification methods, and retains records for examiner review. They coordinate SAR filings and periodic program reviews when issues arise.
The individual or authorized representative completes identity fields, provides required ID documentation, and signs or consents electronically or in person. Accuracy here determines whether the institution can onboard or must decline the relationship.
Include fields to record the specific ID used, issuing authority, expiration, and the verification method (document review, database match, or third-party service) to evidence CIP steps.
Capture full legal name, DOB, SSN/TIN, current address, and contact information; these data points are the basis for identity matching and risk-scoring algorithms.
Document copies, screen captures, or third-party verification reports should be linked to the form and stored to support examiners and potential investigations.
Record timestamps, IP addresses, signer actions, and approver notes to demonstrate who performed each verification step and when.
Retain signed forms and supporting records in encrypted storage with strict access controls and logging to meet regulatory recordkeeping expectations.
Design the form for export to case management, AML monitoring, and core account systems to automate periodic review and SAR-related workflows.
Complete CIP verification before or at account opening.
Refresh records when customer information changes significantly.
Keep CIP records per FinCEN rules (see retention guidance).
File suspicious activity reports promptly per BSA procedures.
Conduct enhanced or periodic reviews for higher-risk customers.