Under CIP, identity verification must be completed before opening an account. Which of the following statements best describes this requirement?

• A. Verifiable identity using documentary evidence
• B. Identity verification is not required for all products
• C. A customer’s identity is optional
• D. Identity verification must be completed before account opening

Answer: (D)

Under CIP, the goal is to Know Your Customer by verifying who is opening an account before any accounts are opened. This verification is a core step in the account-opening process, using either documentary evidence (like a passport or driver’s license) or non-documentary methods to form a reasonable belief of the customer's identity. Because the purpose of CIP is to prevent illicit activity and ensure the institution truly knows who its customer is, the verification must be completed prior to or at the moment of opening the account. The other statements miss this essential timing or requirements: identity verification is not optional, it applies to applicable products and customers, and while documentary evidence is common, CIP also allows other verification methods, but the key point is that verification happens before the account is opened.