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Doing CIP on Jason Bourne

Aug 31, 2016
By: Robin Guthridge
Financial Institutions

Movie goers have been entertained this summer with the next chapter in the saga of Jason Bourne. This popular spy thriller takes us to exotic places around the world, keeping us enthralled as good guys and villains alike scale walls and dodge traffic in their relentless pursuits. Escapades, illusions, and deceptions are not the exception, but the norm.

However, Jason Bourne now has the answer to one of his many questions, that being who is he? In the days of his previous and simpler life, he was a Green Beret and family man named David Webb. After his entire family was killed in a freak plane crash, he was an amnesiac with nothing or no one. So he joined Medusa, an elite Special Forces unit. Under Medusa, Jason Bourne was known by code names such as Delta One and Cain.

In the real world, financial institutions aren’t likely to have to obtain CIP on too many ubiquitous souls such as Jason Bourne. At the very least, their CIP efforts will probably not involve a high-speed car chase down the Las Vegas Strip and crashing into a casino!

Let’s assume, however, that you are a banker in Nixa, Missouri. According to new FinCEN regulations, if Jason Bourne held an ownership interest in Medusa, you might very well be required to obtain CIP on him.  Luckily, most customers are easier to track than Jason Bourne. To learn more about the new FinCEN CIP requirements, click here to read my recent article.



Robin Guthridge, CAMS, CRCM
Director, Compliance
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