TAILIEUCHUNG - FAQs: Final CIP Rule (FINANCIAL CRIMES ENFORCEMENT NETWORK)

The compensation or return theoretically due to or actually gained by a country’s citizens when a country’s resources such as oil or forests are exploited for export has always depended on complex social institutions, property rights and power relations. In an era of increasing trade, investment and financial liberalisation, the relationship between the exploitation of resources and the accrual of benefits to poor citizens is even more difficult. Many analysts of globalisation argue that transnational corporations are able to play countries off against each other to bid down concession prices and corporate taxes when negotiating rights to exploit resources. Thus. | January 2004 Guidance on Customer Identification Regulations Financial Crimes Enforcement Network FAQs Final CIP Rule The staff of the Board of Governors of the Federal Reserve System Federal Deposit Insurance Corporation Financial Crimes Enforcement Network National Credit Union Administration Office of the Comptroller of the Currency Office of Thrift Supervision and the United States Department of the Treasury Agencies are issuing these frequently asked questions FAQs regarding the application of 31 . . This joint regulation implements section 3261 of the USA PATRIOT Act and requires banks savings associations credit unions and certain non-federally regulated banks bank to have a Customer Identification Program CIP . While the purpose of the FAQs document is to provide interpretive guidance with respect to the CIP rule the Agencies recognize that this document does not answer every question that may arise in connection with the rule. The Agencies encourage banks to use the basic principles set forth in the CIP rule as articulated in these answers to address variations on these questions that may arise and expect banks to design their own programs in accordance with the nature of their business. The Agencies wish to emphasize that a bank s CIP must include risk-based procedures for verifying the identity of each customer to the extent reasonable and practicable. It is critical that each bank develop procedures to account for all relevant risks including those presented by the types of accounts maintained by the bank the various methods of opening accounts provided the type of identifying information available and the bank s size location and type of business or customer base. Thus specific minimum requirements in the rule such as the four basic types of information to be obtained from each customer should be supplemented by risk-based verification procedures where appropriate to ensure that the bank has a reasonable belief that it knows each customer s

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