The following Practice Compliance guidance note provides comprehensive and up to date legal information covering:
Client due diligence (CDD) is a central pillar of the anti-money laundering (AML)/counter-terrorist financing (CTF) regime. CDD requirements underpin the Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017 (MLR 2017), SI 2017/692, which came into force on 26 June 2017, as amended by the Money Laundering and Terrorist Financing (Amendment) Regulations 2019, SI 2019/1511 from 10 January 2020. It reflects the provisions of the AML Guide for the Legal Sector published in March 2018.
Where the MLR 2017 apply (see Practice Notes: Money Laundering Regulations 2017—scope and application—law firms and Scope and application of the MLR 2017 for law firms—flowchart), conducting CDD is an absolute requirement. It is not in itself subject to the risk-based approach. Certain components of CDD however, allow for flexibility and positively require risk assessment.
Evidence of identity can be obtained in a number of forms and come from a number of sources. Whatever evidence you rely on, it must cause you to be reasonably satisfied as to your client's identity.
For more information on CDD, see Practice Note: Money Laundering Regulations 2017—client due diligence—law firms.
This Practice Note is intended to act as a guide and contains suggested CDD measures for different types of individual clients and includes CDD guidance in relation to:
individuals established (resident) in high-risk third countries,
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