To aid in the prevention of money laundering and terrorist financing, it is standard practice (except for a small number of situations) to complete your due diligence prior to entering into a business relationship with a customer or prior to an occasional transaction taking place.
Once your customer has been identified and verified there is no requirement to verify their identity again unless a trigger event occurs.
Potential Trigger Events could include:
Your approach to due diligence should not stand still, on-going monitoring should be carried out to allow you to pick up on trigger events which may impact your risk and the level of due diligence that is required. On-going monitoring should include the nature of the business relationship as well as financial sanctions and politically exposed person screening.
Financial sanction lists and politically exposed person databases are continually evolving, with individuals and entities being added, updated or removed. Due to the nature of these lists and databases, on-going screening can be a vital tool to ensure you are aware should your customer become listed.
Looking forward to exhibiting at @PayExpo this week. Come and see us at stand C24.
Looking for CPD? #LegalEx has over 150 certified seminars. Our MD will be speaking about efficient use of the internet for due diligence.
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