Q&As

How do we carry out client due diligence under the Money Laundering Regulations 2017, SI 2017/692 on a person who is unable to provide standard verification documentation?

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Published on LexisPSL on 06/08/2019

The following Practice Compliance Q&A provides comprehensive and up to date legal information covering:

  • How do we carry out client due diligence under the Money Laundering Regulations 2017, SI 2017/692 on a person who is unable to provide standard verification documentation?

How do we carry out client due diligence under the Money Laundering Regulations 2017, SI 2017/692 on a person who is unable to provide standard verification documentation?

If you are conducting work caught by the Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017 (MLR 2017), SI 2017/692 (see Practice Note: Money Laundering Regulations 2017—scope and application—law firms), you must apply client due diligence (CDD) measures where you:

  1. establish a business relationship

  2. carry out an occasional transaction:

    1. that amounts to a transfer of funds within the meaning of Article 3.9 of the funds transfer regulations exceeding €1000, or

    2. that amounts to €15,000 or more, whether executed in a single operation or in several operations which appear to be linked

  3. suspect money laundering or terrorist financing, or

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