USA BSA/CIP/CDD Rule¶
Definition¶
The US AML framework is built on the Bank Secrecy Act (BSA), the Customer Identification Program (CIP) rule, and the Customer Due Diligence (CDD) Rule — administered by FinCEN.
Framework Components¶
| Component | What It Requires |
|---|---|
| BSA (1970) | Record-keeping for transactions >$10,000, CTR filing |
| USA PATRIOT Act (2001) | CIP requirement, enhanced due diligence for correspondent banking |
| CIP Rule (2003) | Verify identity of each customer: name, DOB, address, ID number |
| CDD Rule (2016) | Identify and verify beneficial owners (25%+), risk-based ongoing monitoring |
| FinCEN BOI (2024) | Beneficial Ownership Information reporting to FinCEN |
CIP Minimum Requirements¶
| Requirement | Details |
|---|---|
| Name | Full legal name |
| Date of birth | For individuals |
| Address | Residential or business |
| Identification number | SSN (US persons) or passport/national ID (non-US) |
| Verification | Documentary (ID document) OR non-documentary (credit bureau, public records) |
Key Takeaways¶
Summary
- USA has no national digital ID — CIP relies on document verification or database checks
- Method-agnostic: regulations don't prescribe specific eKYC technology — "reasonable belief" standard
- CDD Rule added beneficial ownership requirements in 2016
- FinCEN BOI (2024) creates federal beneficial ownership registry
- 50+ state-level driving license formats make document verification more complex than countries with national ID