This section looks at the type of information you may look to collect from a customer as part of the due diligence process. This is not a definitive list and not all pieces of information may be relevant for all businesses. We have provided this as a starting point to help get you started and thing about what your requirements may be.
Personal Identification Information
Understanding the full name of your client including any middle, previous or alias names is important for obtaining a clear picture on you client. This will also be useful should you need to undertake any further research.
Knowing the home address of you client is a must but understanding their previous address is another important factor. If further research is required this may help uncover information that may not have come to light. It can also enable you to discount potentially negative information too. For both of these reasons knowing the dates the client resided at the addresses is also important. If you use a solution to electronically identify your client the previous address will usually be used to before additional fraud prevention checks by looking at data consistency.
It may be that your client requests you to use a contact address. This adds in additional risk that your client may not be the individual at the home address. Consideration should be given to making some contact via the home address to confirm your client is who they say they are. Documenting the reason for the use of a different address ensures consideration has been given to the risk.
Understanding the employment position of you client and detail of that employment will be a great help when looking to assess the money laundering risk of a client. For example a self-employed client running a business with a high cash throughput will generally be higher risk due to the ease at which criminal proceeds can be mixed in with legitimate funds.
The location in which your client is living or working may be a factor in increasing the risk they bring. In some countries the approach to anti-money laundering and the prevention of bribery and corruption is not sufficiently enforced. This could result in a potential for criminal funds to filter through your business.
The method in which a client is interacted with will adjust the associated risk. Having a relationship where a client is never met face to face is at higher risk for fraud and steps should be taken to minimise the risk.
It may be that your business only provides a single core service and therefore the level of risk will be consistent. However, where different product or services are offered you may wish to adapt the level of due diligence undertaken based on this risk.
Understanding what will be normal for your client will enable you to identify when something abnormal happens. There may be a valid reason for changes in your client’s activity such as a significant increase in the amounts going through your business. However, it could be an indicator to a change in the risk the client brings warranting a higher level of due diligence.
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