In order to detect any of the red flags identified in Article III that are associated with the opening of a new account, City of El Paso personnel must take the following steps to obtain and verify the identity of the person opening the account:
A. 
Require certain identifying information such as name, date of birth, residential or business address, principal place of business for an entity, and a driver's license or other identification;
B. 
Verify the customer's identity (for instance, review a driver's license or other identification card);
C. 
Review documentation showing the existence of a business entity; and
D. 
Independently contact the customer.
In order to detect any of the red flags identified in Article III that are associated with the operation of an existing account, City of El Paso personnel must take the following steps to monitor transactions with an account:
A. 
Verify the identification of customers if they request information (in person, via telephone, via facsimile, or via e-mail).
B. 
Verify the validity of any requests to change a billing address; and
C. 
Verify any change in banking information that is given for billing and payment purposes.