Remember that whatever you put into a policy document with respect to procedures must be monitored and tested periodically. How do you know any checklist works if you are not monitoring and testing its effectiveness?
The USA Patriot Act is a foundational Act for Customer Identification Procedures (CIP), and any checklist must conform with the Act’s mandates.
In my view, your checklist should contain at least four procedural features: verifying identity, recordkeeping, list-checking, and customer notice.
Let’s consider each of them in a checklist format.