Questions and Answers
Do the CIP regs apply to requests for wire transfers?
No. The customer identification program (CIP) regs apply when an account is opened. The regulations define “account” to include “a formal banking relationship established to provide or engage in services, dealings, or other financial transactions”. This definition further states that an account does not include:
...( A) A product or service where a formal banking relationship is not
established with a person, such as check-cashing, wire transfer, or sale of a check or money order... See 31 CFR 103.121 (a) (1)(i).
