Anti-money laundering policy
Customer due diligence (client identification procedure)
Standard customer due diligence
Where we are carrying out certain regulated business (accountancy, audit and tax services and legal services re financial, company or property transactions) and as part of this:
- forms an ongoing business relationship with a client
- undertakes a one off or occasional transaction amounting to €15,000 (approximately £13,000) or more (whether carried out as a single transaction or several linked ones)
- suspects money laundering or terrorist financing
then the customer due diligence procedure must be followed before any business is undertaken for that client. This means identifying the customer and verifying the customer's identity on the basis of information obtained from a reliable and independent source.
Enhanced customer due diligence (and ongoing monitoring)
It will in certain circumstances be necessary to undertake what is known in the regulations as enhanced customer due diligence. In summary, this will be necessary where:
- the customer has not been physically present for identification purposes
- in any other situation which by its nature can present a higher risk of money laundering or terrorist financing
Where this applies, we will need to take adequate measures to compensate for the higher risk. For example, this will mean ensuring that the customer's identity is established by additional documents, data or information and ensuring ongoing monitoring is carried out for the duration of the business relationship.
Similarly, where we are in an ongoing 'business relationship' with a customer, the Regulations impose a special obligation to carry out ongoing monitoring.