Customer Identity Verification KYC Check Checklist [FREE PDF]

The Bank Secrecy Act and its implementing regulations under 31 CFR Chapter X require financial institutions to establish and maintain effective Customer Identification Programs (CIP) and Know Your Customer (KYC) procedures to detect and prevent money laundering, terrorist financing, and other financial crimes. FinCEN's Customer Due Diligence (CDD) rule, effective May 2018, further requires beneficial ownership identification for legal entity customers and ongoing monitoring of customer relations

Industry: Banking
Frequency: Per Event
Estimated Time: 20-35 minutes
Role: Compliance Officer
Total Items: 36
Compliance: BSA/AML - Bank Secrecy Act 31 USC 5311 et seq., FinCEN CDD Rule 31 CFR §1010.230 - Beneficial Ownership, 31 CFR §1020.220 - Customer Identification Program Requirements, FFIEC BSA/AML Examination Manual 2022, Dodd-Frank Act Section 1071 - Small Business Data Collection

Customer Identification Program (CIP) Verification

Verify that minimum CIP requirements are met by collecting and validating required identity information before account opening.

Has the customer's full legal name been collected and verified against a government-issued photo ID?
Has the customer's date of birth (for individuals) been collected and recorded?
Has a residential or business street address been collected and is it a valid non-PO Box address?
Has a taxpayer identification number (SSN, EIN, or ITIN) been collected for the customer?
Have identity documents been verified through documentary or non-documentary means per the bank's CIP policy?
Has the customer been informed that identity information is being collected for verification purposes?

Identity Document Verification

Assess the authenticity and completeness of identity documents presented by the customer.

Is the primary identity document (passport, driver's license, or national ID) unexpired?
Does the photo on the ID document match the physical appearance of the customer presenting it?
Have document security features (holograms, watermarks, microprint) been visually inspected for authenticity?
Has a photocopy or digital scan of all identity documents been retained per the bank's record retention policy?
For foreign nationals, has an acceptable foreign passport or other approved non-US document been obtained?

Beneficial Ownership & Controlling Parties (Legal Entities)

Collect and verify beneficial ownership information for legal entity customers as required by FinCEN CDD Rule.

Has a completed Beneficial Ownership Certification Form been obtained from an authorized representative?
Have all individuals owning 25% or more of the legal entity been identified and verified?
Has one individual with significant managerial control (control prong) been identified and verified?
Has the legal entity's formation documentation (articles of incorporation, LLC agreement) been reviewed?
Are there any complex ownership structures or shell company indicators that require enhanced review?

OFAC Sanctions & Watchlist Screening

Verify that the customer and associated parties have been screened against OFAC and other required watchlists.

Has the customer's name been screened against the OFAC Specially Designated Nationals (SDN) list?
Have all beneficial owners and controlling persons been individually screened against OFAC SDN list?
Has the customer been screened against FinCEN 314(a) and any applicable government watchlists?
Were any potential OFAC or watchlist matches identified requiring further investigation or blocking?
Is the screening result documented with the date, database version, and screening outcome?

Customer Risk Rating & Due Diligence Level

Assign a risk rating to the customer and determine the appropriate level of due diligence required.

Has a formal customer risk rating been assigned based on the bank's risk scoring methodology?
What is the assigned customer risk rating for this account?
Is the customer's stated business purpose and expected account activity consistent and plausible?
Has Enhanced Due Diligence (EDD) been triggered for high-risk customers (PEPs, high-risk geographies, MSBs)?
Has the anticipated transaction volume and product usage been documented for ongoing monitoring baseline?

Politically Exposed Person (PEP) & High-Risk Category Screening

Identify whether the customer qualifies as a PEP, foreign official, or falls into other high-risk categories requiring escalated review.

Has the customer been screened against commercial PEP databases and government official lists?
Is the customer or any beneficial owner a current or former senior government official, military officer, or judiciary?
Is the customer's country of origin or primary business operations on an FATF grey list or high-risk jurisdiction list?
Does the customer operate as or in connection with a Money Service Business (MSB)?
If PEP or high-risk designation applies, has senior management approval been obtained before account opening?

Record Retention & Documentation Completeness

Confirm that all KYC and CIP records are complete, accurate, and stored per regulatory retention requirements.

Are all CIP verification records being retained in the bank's system of record for a minimum of five years?
Is the KYC file complete with all required fields populated and no unexplained gaps in documentation?
Has the customer's KYC profile been scheduled for periodic review based on their assigned risk rating?
Are there any suspicious activity indicators observed during this KYC review requiring a SAR evaluation?
Additional notes, discrepancies, or follow-up actions identified during this KYC review?

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Why Use This Customer Identity Verification KYC Check Checklist [FREE PDF]?

This customer identity verification kyc check checklist [free pdf] helps banking teams maintain compliance and operational excellence. Designed for compliance officer professionals, this checklist covers 36 critical inspection points across 7 sections. Recommended frequency: per event.

Ensures compliance with BSA/AML - Bank Secrecy Act 31 USC 5311 et seq., FinCEN CDD Rule 31 CFR §1010.230 - Beneficial Ownership, 31 CFR §1020.220 - Customer Identification Program Requirements, FFIEC BSA/AML Examination Manual 2022, Dodd-Frank Act Section 1071 - Small Business Data Collection. Regulatory-aligned for audit readiness and inspection documentation.

Frequently Asked Questions

What does the Customer Identity Verification KYC Check Checklist [FREE PDF] cover?

This checklist covers 36 inspection items across 7 sections: Customer Identification Program (CIP) Verification, Identity Document Verification, Beneficial Ownership & Controlling Parties (Legal Entities), OFAC Sanctions & Watchlist Screening, Customer Risk Rating & Due Diligence Level, Politically Exposed Person (PEP) & High-Risk Category Screening, Record Retention & Documentation Completeness. It is designed for banking operations and compliance.

How often should this checklist be completed?

This checklist should be completed per event. Each completion takes approximately 20-35 minutes.

Who should use this Customer Identity Verification KYC Check Checklist [FREE PDF]?

This checklist is designed for Compliance Officer professionals in the banking industry. It can be used for self-assessments, team audits, and regulatory compliance documentation.

Can I download this checklist as a PDF?

Yes, this checklist is available as a free PDF download. You can also use it digitally in the POPProbe mobile app for real-time data capture, photo documentation, and automatic reporting.