The following Risk & Compliance practice note provides comprehensive and up to date legal information covering:
You may apply simplified customer due diligence (SDD) measures in relation to particular business relationships or transactions which you determine present a low risk of money laundering or terrorist financing, having taken into account:
your organisation-wide risk assessment—see Practice Note: Money Laundering Regulations 2017—identifying and assessing organisation-wide risks and Precedent: Money laundering and terrorist financing organisation-wide risk assessment
relevant information made available to you by your supervisory authority, and
the risk factors set out at Assessing the risk below
This Practice Note explains your options around SDD and what it means for you in practice. It reflects the Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017 (MLR 2017), SI 2017/692. The MLR 2017 have been amended since implementation to address developing requirements in Europe before Brexit and Brexit itself (eg through the Money Laundering and Terrorist Financing (Amendment) Regulations 2019, SI 2019/1511, and the Money Laundering and Terrorist Financing (Amendment) (EU Exit) Regulations 2020, SI 2020/991). 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 SDD.
SDD is the lowest level of due diligence that can be completed on a customer. It is only permitted where there
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