What is one additional requirement of the MDD process beyond the CIP requirements?

The additional requirement of the Member Due Diligence (MDD) process that goes beyond the Customer Identification Program (CIP) requirements is that institutions must understand the nature and purpose of member relationships. This is critical because thorough understanding helps financial institutions assess the potential risk associated with each member. By analyzing the nature of the relationship and its purpose, institutions can effectively identify and mitigate potential risks of money laundering or other illicit activities tied to the member's account.

This requirement builds on the CIP by not just identifying who the member is, but also by actively assessing their transaction behaviors and the expected patterns of activity. This deeper insight allows institutions to implement appropriate risk management practices, ensuring compliance with the Bank Secrecy Act and related regulations. Understanding the members' relationships can also facilitate better monitoring of transactions, enabling proactive identification of suspicious activity.