AML/CFT Supervisors issue new Enhanced Customer Due Diligence Guideline

The AML/CFT Supervisors have issued a new Enhanced Customer Due Diligence (EDD) Guideline and this provides additional detail on what is expected of reporting entities. This guideline covers the following as well as the collection and verification of source of wealth and source of funds:
 

  • When is EDD required;
  • When must EDD be conducted for new customers;
  • When must EDD be conducted again?
  • When must EDD be conducted for existing customers?
  • How important is “nature and purpose” for EDD?
  • What does “material change” mean for EDD purposes?
  • What if you cannot complete EDD?
  • Can you delay identity verification during EDD?
  • What EDD record keeping do you need to do?
  • Do you need EDD as part of your training?
  • Can you conduct EDD via a third party?
  • Obtaining and verifying identity information

All reporting entities should review their AML/CFT Programmes taking this guidance into consideration.

NationalPhil Houghton