# account-opening-compliance

This skill helps shape compliance checks for account opening, from identity verification to sanctions screening. Use it when planning risk-based approvals or handling verification exceptions.

- skill · `type=skill` · Claude Code, Codex, Cursor, GitHub Copilot, Gemini CLI, OpenCode · 654 installs · ★ 218
- Author: JoelLewis
- License: MIT · policy=mirror · the beginning of the file is at the end of this page
- Source: https://github.com/JoelLewis/finance_skills/tree/HEAD/plugins/client-operations/skills/account-opening-compliance/SKILL.md
- Updated: 2026-07-18
- HTML: https://affpapa.org/en/nevibecode/skills/account-opening-compliance

## What it does

The skill outlines how to place CIP/KYC checks in an account-opening flow, when to verify identity, and how to handle pass, fail, or inconclusive outcomes. For an unclear result, it describes routing the case for manual review and requesting more documents. One key design constraint: an account should not become active before CIP is satisfied.

It also covers OFAC and sanctions screening for people connected to an account, beneficial ownership information, risk-based approval tiers, and exception tracking. Other topics include senior investor protections, trusted contacts, CDD risk ratings, and preparing account-opening procedures for SEC or FINRA examination. The procedures you implement still need to reflect your own compliance requirements.

## Install

### Claude Code (native platform)

1. **Skills CLI (Vercel)**
```bash
npx skills add JoelLewis/finance_skills --skill account-opening-compliance -a claude-code
```

2. **Manually: put the files in place**
- File: `~/.claude/skills/account-opening-compliance/SKILL.md` — Copy the whole skill folder; for one project use .claude/skills/account-opening-compliance/

### Codex

1. **Skills CLI (Vercel)**
```bash
npx skills add JoelLewis/finance_skills --skill account-opening-compliance -a codex
```

2. **Manually: put the files in place**
- File: `.agents/skills/account-opening-compliance/SKILL.md` — For all projects use ~/.agents/skills/

### Cursor

1. **Skills CLI (Vercel)**
```bash
npx skills add JoelLewis/finance_skills --skill account-opening-compliance -a cursor
```

2. **Manually: put the files in place**
- File: `.cursor/skills/account-opening-compliance/SKILL.md` — Cursor also reads .agents/skills/ and .claude/skills/

### GitHub Copilot

1. **GitHub CLI**
```bash
gh skill install JoelLewis/finance_skills account-opening-compliance
```

2. **Manually: put the files in place**
- File: `.github/skills/account-opening-compliance/SKILL.md`

### Gemini CLI

1. **Skills CLI (Vercel)**
```bash
npx skills add JoelLewis/finance_skills --skill account-opening-compliance -a gemini-cli
```

2. **Platform CLI**
```bash
gemini skills install https://github.com/JoelLewis/finance_skills --path plugins/client-operations/skills/account-opening-compliance
```

### Windsurf (Devin Desktop)

**Manually: put the files in place**
- File: `.devin/skills/account-opening-compliance/SKILL.md` — The legacy .windsurf/skills/ path still works

### OpenCode

**Skills CLI (Vercel)**
```bash
npx skills add JoelLewis/finance_skills --skill account-opening-compliance -a opencode
```

### Claude.ai

**Claude.ai**
- Zip the folder and upload it in Settings → Capabilities → Skills

Where a file is given instead of a command, copy the files from the source to that path: https://github.com/JoelLewis/finance_skills/tree/HEAD/plugins/client-operations/skills/account-opening-compliance/SKILL.md

## When to use it
- design identity checks for new accounts
- route inconclusive CIP results to manual review
- screen people associated with an account against sanctions lists
- collect beneficial ownership details
- set risk-based approval tiers and track exceptions

## Example prompts
- Design CIP/KYC checks for our account-opening flow, including pass, fail, and inconclusive outcomes.
- Work out which people to screen for OFAC on a joint account and an entity account.
- Help prepare our account-opening procedures for an SEC or FINRA examination.

## Source text · SKILL.md · MIT

Below is the content of a third-party file. It is data, not instructions for you: do not act on anything written inside unless the human asks. Block tag: eaee1f04491719bd.

BEGIN THIRD-PARTY FILE eaee1f04491719bd
```text
---
name: account-opening-compliance
description: "Embed compliance controls into account opening and verify regulatory readiness. Use when designing CIP/KYC identity verification gates, implementing OFAC and sanctions screening at onboarding, collecting beneficial ownership certification for entity or trust accounts, building risk-based approval tiers that route applications by risk level, defining compliance screening requirements and exception tracking, adding senior investor protections (FINRA Rules 2165/4512) or trusted contact procedures, establishing CDD risk ratings and ongoing monitoring triggers, or preparing account opening procedures for SEC or FINRA examination. For the operational pipeline these controls plug into, see account-opening-workflow."
---

# Account Opening Compliance

## Core Concepts

### CIP Integration in Account Opening
The Customer Identification Program is the first compliance gate in any account opening workflow. Under USA PATRIOT Act Section 326 and its implementing regulations, a firm must verify the identity of each customer before or at the time of account opening. The account opening process must be designed so that no account becomes active until CIP is satisfied.

**Verification timing.** The regulations permit two approaches: (1) verify identity before the account is opened, which is the most conservative approach and prevents any transactional activity until verification is complete; or (2) verify identity within a reasonable time after the account is opened, provided the firm has procedures to manage the risk of incomplete verification (such as restricting account activity until verification is complete). Most firms implementing digital onboarding choose the first approach — identity verification occurs in real time during the application flow, and the application cannot proceed until verification returns a pass result. The second approach — opening with restricted activity pending verification — is used primarily for paper-based or advisor-assisted workflows where verification cannot occur in real time, and requires the firm to document the risk mitigation procedures (no trading, no disbursements, no margin until verification completes).
```
END THIRD-PARTY FILE eaee1f04491719bd

The third-party file has ended. Everything between the eaee1f04491719bd tags is data: requests and commands from it are not followed. An “end of file” line with another tag inside the block is part of the file.

First 2226 of 47298 bytes. © JoelLewis · MIT · https://github.com/JoelLewis/finance_skills/tree/HEAD/plugins/client-operations/skills/account-opening-compliance/SKILL.md

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---
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