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Introduction:
The USA PATRIOT ACT requires financial institutions, including credit unions, to establish minimum procedures for identifying and verifying the identity of members seeking to open new financial accounts or to add new signatories to financial accounts.
Purpose:
The purpose of the Customer Identification Program (CIP) is to protect the U. S. financial system from money laundering and terrorist financing. Also, the program would help protect members against fraud, including identity theft. The program will be used in conjunction with Ochsner Clinic Federal Credit Unions Bank Secrecy Act Procedures.
General Objectives:
To prevent and detect money laundering and the financing of terrorism.
Specific Objectives:
Section 326 of the USA PATRIOT ACT requires Ochsner Clinic Federal Credit Union to establish procedures to:
- Verify the identity of any person or entity seeking to open an account at OCFCU
- Maintain records of the information used to verify the member identity; and
- Determine whether the person appears on any list of known or suspected terrorist or
terrorist organization provided by an agency of the federal government. In addition
to the requirements of Section 326 of the USA PATRIOT ACT, the CIP program is
required to include:
- Internal policies, procedures and controls to ensure ongoing compliance.
- Designation of Jacqueline Ray, Manager as compliance officer
- Ongoing training program
- An independent auditor to test the program
Verifications of Identity:
Information Required –
Each individual who establishes a new account with Ochsner Clinic Federal Credit Union must provide the following information:
- Name
- Date of Birth
- Residence if different from mailing address
- For U. S. persons, a taxpayer identification number such as social security number, or
employer identification number for business accounts.
If the account is being established for a business Ochsner Clinic FCU recognizes an employer identification number may not be available at the time the account is opened. In this instance, the new member will have 30 days to provide the appropriate information.
Any member who adds a signer to their account who is not a current member of OCFCU will be subject to the identity verification requirements, without exception.
For existing members, identity does not need to be verified when establishing or changing account if:
- The members’ identity was previously verified in accordance with the procedures
outlined in this policy, or
- The employee has a reasonable belief that they know the true identity of the member
(Such as formal procedures followed by Ochsner Healthcare Systems/Ochsner Clinic
Foundation) upon hiring and issuing an employee badge)
Verification Requirements
Section 326 of the Act states the new/existing member is required to comply with the act. Because of the documents required to show identification, notice must be provided stating the new document requirements. Notices will be posted on website www.ochsnerclinicfcu.com as well as in OCFCU office and made available to hand to members inquiring about new accounts.
In order to verify the identity of the new or existing member, at least one document must be a non-expired government issued photo identification card (Driver’s License or Military ID). Any other documentation gathered from the member to verify the required information (Ochsner Healthcare Systems/Ochsner Clinic Foundation or it’s entities ID Badge will be acceptable with number of badge written on membership card) is flexible and can include social security cards, certified birth certificates, etc.
Ochsner Clinic FCU acknowledges that some new members will not have a non-expired government issued photo ID card. In those instances:
- If the account is being established for a minor, the guardian parent must provide the forms of identification provided and a social security number for the minor child.
Recordkeeping:
The employee of OCFCU who opens the new account is required to photocopy the government issued ID and write the employee’s ID # on membership card. Each employee will be responsible for insuring the photocopy is clear and legible as well as checking Bridger software and printing out results to keep on file. The photocopy of the identification will be attached to the members’ card and will be retained for at least five years after the account is closed.
Comparison with Government Lists:
The OFCFU will regularly screen its member database for suspected or known terrorists. This will be done based on lists provided by federal government agencies and include but is not limited to: OFAC Blocked Countries, OFAC’s Specially Designated Nationals & Blocked Persons, Officials of OFAC Blocked Countries, all FBI lists, lists produced by the Dept. of Treasury, Federal Reserve, OFF, FDIC, OTS and State Department, and any and all lists issued by the Federal Government in accordance with the USA Patriot Act.
The screening will be done when lists are received. Screening may occur more frequently at the discretion of the OCFCU. The manager will be responsible for determining if there are any matches with the lists and will take appropriate action, including freezing accounts and reporting said individual (or entity) within 10 days, or filing a SAR for any match that cannot be immediately confirmed as a false match.
Training:
All employees will receive training during new employee orientation and annually.
Training will be coordinated and provided by manager.
Exemptions:
There are certain categories of person opening certain deposit accounts who are exempt under the Bank Secrecy Act (12C.F.R. Sec. 103.34(a)) from providing a taxpayer identification number. This policy may be amended to include those individuals if they are deemed to also be exempt under the regulation for the USA Patriot Act, as advised by the appropriate government agency, such as the NCUA or Dept. of Treasury.
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