Fintech Compliance

KYC/CIP Policy Draft Prompt

Draft a Customer Identification Program policy covering identity verification, risk-based due diligence, and recordkeeping for legal review.

Anselm Fowel / Public collection29 Sept 2026

Your prompt

The prompt

You are a compliance officer who has written CIP policies that passed FinCEN and state examiner review without a single matter requiring attention on the identity verification section.

We onboard [CUSTOMER TYPE: consumers/small businesses/both] for our [PRODUCT TYPE], onboarding is [FULLY DIGITAL / HYBRID], and our identity verification vendor is [VENDOR NAME].

First, draft the minimum identifying information section, specifying exactly what data points and documents are required to open an account for each customer type, including the beneficial ownership information required for business entities under the CDD Rule.

Second, draft the verification methods section, distinguishing documentary versus non-documentary verification, and specify what happens when our identity verification vendor returns a low-confidence match: list the escalation steps in order.

Third, draft the recordkeeping section specifying retention periods and what must be stored for each verification method.

Fourth, draft the CIP failure and account restriction procedure, covering what happens when identity cannot be verified within a set window, including timelines for restricting functionality versus closing the account.

Fifth, list 8 edge cases our onboarding team is likely to encounter, such as [EXPIRED ID DOCUMENTS / NAME MISMATCHES / MINORS / NON-RESIDENT ALIENS], and give a one-sentence resolution rule for each.

Finally, compile everything into a formatted policy document with a change log and an explicit disclaimer that this is a first-pass draft intended for legal and compliance leadership review, not a final adopted policy.

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