Question

Difficulty: EasyAnti-Money Laundering (AML), KYC, and Sanctions Compliance

Under federal Anti-Money Laundering (AML) regulations and FINRA rules, broker-dealers must establish a Customer Identification Program (CIP) to verify the identity of individuals opening accounts. Which of the following customer details are mandatory minimum information elements that a firm must collect from an individual U.S. citizen prior to opening an account?

  1. Legal name and date of birthAnswer
  2. Taxpayer Identification Number (such as a Social Security Number)Answer
  3. C
    Copies of personal federal income tax returns from the previous two years
  4. Physical residential or principal business street addressAnswer

Answer

The mandatory minimum CIP information required from an individual U.S. person prior to account opening includes the customer's legal name, date of birth, Taxpayer Identification Number (Social Security Number), and a physical residential or business street address.
Federal CIP rules mandate that broker-dealers collect four specific minimum pieces of information from a U.S. individual before opening an account: legal name, date of birth, physical residential or business street address, and a Taxpayer Identification Number.

Step-by-Step Solution

1
Identify the mandatory minimum Customer Identification Program (CIP) identity requirements under federal AML regulations.
The four required data points are: (1) Legal Name, (2) Date of Birth, (3) Physical Street Address, and (4) Taxpayer Identification Number.
FinCEN and FINRA rules require collecting these four core items to form a reasonable belief regarding the true identity of each customer.
2
Evaluate the choices to determine which are mandatory identity elements.
Legal name and DOB, Taxpayer Identification Number, and physical street address are required. Income tax returns are not part of basic CIP identity requirements.
Distinguishing basic identity verification requirements from financial suitability documents prevents regulatory misinterpretation.

Key Concept

Mandatory Customer Identification Program (CIP) Information Requirements
Estimated Time:45s
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