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Customer ID Program

 

CIP

Verify & document the identity of customers opening new accounts

 

Customer Due Diligence

 

CDD

Verify identity with documentary means & non-documentary means

 

Enhanced Due Diligence

 

EDD

Required for correspondent & offshore financial institutions

 

 

EDD

Required for correspondent & offshore financial institutions

 

Customer Identification Program

Pangeodata provides Compliance Officers and Designees with all the data sources required to meet the demands of Customer Identification Programs (CIP). Our due diligence services provide the verifications and data searches required for the Bank Secrecy Act (BSA), OFAC, the US Patriot Act, and FinCEN Compliance.

  • Bank Secrecy Act (BSA)
  • OFAC
  • US Patriot Act
  • FinCEN

OFAC Sanctions List

Pangeodata searches OFAC lists to meet basic compliance requirements of CIP:

  • OFAC Specially Designated Nationals List (SDN)
  • OFAC Consolidated Sanctions List

 

Non-Documentary Methods

Pangeodata offers options for basic ID verification based on whether the customer has the required documents. Methods for non-documentary ID verification include:

  • Data ID Number Search
  • Financial References
Documentary Method

Best practices dictate CIP identification verification through a documentary method. Pangeodata offers the world’s most innovative products for ID verification through documentary methods such as:

  • CatfishID
  • CatfishAIR
  • ValidID
  • Vix Verify
  • Vix Verify Biometrics
Report
  • Compliant turnaround time
  • Minimum five-year (5) retention
  • AML-required reports format
  • Annual employee training as required by CIP
  • Ongoing monitoring
Private Banking

Private banking must run a Politically Exposed Persons (PEP) search for any non-U.S. citizen account holder and their immediate family

Ongoing Monitoring

For both customer and any principals or signatures on the account ongoing monitoring of:

  • OFAC
  • PEP
  • Due Diligence Sanctions search

Customer Due Diligence

An indication a customer ID verification should be escalated is if they have transactions involving high-risk jurisdictions.

 

Customer ID Due Diligence

For both customers and any principals or signatures on the account:

  • Verify Occupation
  • Academic Verification
  • Professional Licenses
  • Regulated Industry Sanctions
  • Criminal History
  • Credit Report
Business Credit Standing

For both customers and any principals or signatures on the account:

  • Credit References
  • Business Credit Reports
  • Banking References
Corporate Structure
  • Verify ownership & principals
  • Verify type of business
  • Verify in-country registration
  • Verify business licenses
Additional searches
  • Adverse media search
  • Due diligence sanctions search
Ongoing Monitoring

The ongoing monitoring, for both customers and any principals or signatures on the account, of:

  • OFAC
  • PEP
  • Due diligence sanctions search

Enhanced Due Diligence

An enhanced level of search and verification on customers that pose a high-risk, such as:

  • an offshore banking license
  • a banking license issued by a foreign country designated as non-cooperative with international AML principals and procedures
  • a banking license issued by a foreign country that has been designated by the Secretary of the Treasury as warranting special measures due to money laundering concerns

 

Nominal Holders ID

All searches conducted on the customer in basic CIP and due diligence should be conducted on any nominal holder and holders of beneficial ownership interest

Membership & Licensing
  • Corporate and individual memberships in trade associations
  • Professional or corporate licensing above what is required to do business
Onsite Visit

Pangeodata sends a representative to the customer’s place of business to verify the address and operations, as well as any necessary documents with photographs

Country Records Search

This search is to look at a country individually and search all government records available in that country or region. Accessibility varies based on the country.

Expanded Searches

Local Language Media Search

Social & Adverse Media Search