• AML 8.5 AML 8.5 Simplified Customer Due Diligence

    • AML 8.5.1 AML 8.5.1

      (1) Where a Relevant Person is permitted to undertake Simplified CDD under Rule 8.1.1(2), modification of Rule 8.3.1 may include:
      (a) verifying the identity of the customer and any Beneficial Owners after the establishment of the business relationship;
      (b) deciding to reduce the frequency of, or as appropriate not undertake, customer identification updates;
      (c) deciding not to verify an identification document other than by requesting a copy;
      (d) reducing the degree of on-going monitoring of Transactions, based on a reasonable monetary threshold or on the nature of the Transaction; and
      (e) not collecting specific information or carrying out specific measures to understand the purpose and intended nature of the business relationship, but inferring such purpose and nature from the type of Transactions or business relationship established.
      (2) The modification undertaken under (1) must be proportionate to the customer's money laundering risks.
      Amended on (15 April, 2019).

      • Guidance

        1. Relevant Person should not use a "one size fits all" approach for all of its low-risk customers. Notwithstanding that the risks may be low for all such customers in that category, the extent of CDD undertaken needs to be proportionate to the specific risks identified on a case by case basis.
        2. A Relevant Person might reasonably reduce the frequency of or, as appropriate, eliminate customer identification updates where the money laundering risks are low and the service provided does not offer a realistic opportunity for money laundering.
        3. An example of where a Relevant Person might reasonably reduce the degree of on-going monitoring and scrutinising of Transactions, based on a reasonable monetary threshold or on the nature of the Transaction, would be where the Transaction is a recurring, fixed contribution to a savings scheme, investment portfolio or fund or where the monetary value of the Transaction is not material for money laundering purposes given the nature of the customer and the Transaction type.
        Amended on (15 April, 2019).