Money Laundering Regulations 2017—customer due diligence
Money Laundering Regulations 2017—customer due diligence

The following Risk & Compliance guidance note provides comprehensive and up to date legal information covering:

  • Money Laundering Regulations 2017—customer due diligence
  • CDD triggers
  • Conducting CDD for work not caught by the MLR 2017
  • What is CDD?
  • Identification of customer and verification of their identity
  • Purpose and intended nature of the business relationship
  • CDD and existing customers
  • Applying CDD measures
  • Timing of CDD
  • Requirement to report discrepancies in registers
  • more

This Practice Note provides guidance on customer due diligence (CDD) which is a central pillar of the anti-money laundering (AML) and 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, as amended by the Money Laundering and Terrorist Financing (Amendment) Regulations 2019, SI 2019/1511 from 10 January 2020. It provides guidance which is of general application. You should check whether the MLR 2017 contain additional or varied requirements for your sector and whether your regulatory body has any additional, sector specific requirements in relation to CDD.

Where the MLR 2017 apply, 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.

CDD triggers

You must apply CDD measures when 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 regulation 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

  4. doubt the veracity or adequacy of documents or information previously obtained for the purposes of identification or verification