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Establish, implement, and maintain a customer due diligence program.


CONTROL ID
13618
CONTROL TYPE
Establish/Maintain Documentation
CLASSIFICATION
Preventive

SUPPORTING AND SUPPORTED CONTROLS



This Control directly supports the implied Control(s):
  • Establish, implement, and maintain a Customer Information Management program., CC ID: 00084

This Control has the following implementation support Control(s):
  • Include ongoing monitoring in the customer due diligence program., CC ID: 16629
  • Retain records of the measures taken during customer due diligence., CC ID: 16605
  • Determine if customer due diligence measures are needed for existing customers., CC ID: 16604
  • Analyze the appropriateness of the customer due diligence program, as necessary., CC ID: 13621


SELECTED AUTHORITY DOCUMENTS COMPLIED WITH



  • Where a firm cannot apply customer due diligence measures, including where a firm cannot be satisfied that it knows who the beneficial owner is, it must not enter into, or continue, the business relationship. (3.2.4 ¶ 8, Financial Crime Guide: A Firm’s Guide to Countering Financial Crime Risks, Release 11)
  • Customer identification program. Each federally insured credit union is subject to the requirements of 31 U.S.C. 5318(l) and the implementing regulation jointly promulgated by the NCUA and Department of the Treasury at 31 CFR 1020.220, which require a customer identification program to be implemente… (§ 748.2 (b)(2), 12 CFR Part 748, NCUA Guidelines for Safeguarding Member Information, July 1, 2001)
  • A copy of a police report evidencing the claim of the victim of identity theft. (§ 445.71(1)(a)(i), Michigan Identity Theft Protection Act, Act 452 of 2004, Sections 445.61 thru 445.72a)
  • If the consumer or protected consumer is the victim of identity theft or has reported a theft of personal information to a law enforcement agency, the consumer or representative may include a copy of the police report, incident report or identity theft declaration. (§ 646A.606(2), Oregon Revised Statutes, Chapter 646a, Sections 646A.600 thru 646A.624, Identity Theft Protection Act, 2007 Statutes)