The following Practice Compliance precedent provides comprehensive and up to date legal information covering:
You must complete this form for all new clients[ who are subject to the anti-money laundering (AML) and counter-terrorist financing (CTF) regime. If you are unsure whether the AML/CTF regime applies, please seek guidance from [state who]].
You must also complete this form for existing clients, where:
there has been a gap in contact of [three] years or more
the circumstances of an existing client have changed (eg identity/beneficial owner, etc)
a proposed matter/transaction is not consistent with our knowledge of the client
there is a change in the purpose or intended nature of our relationship with the client
there is any other matter which affects our assessment of the risk of money laundering or terrorist financing the client presents
We are required to undertake client due diligence (CDD)[ where the AML/CTF regime applies]. In high-level terms, CDD involves identifying and verifying the client (unless they are already known to us) and assessing the purpose and intended nature of the matter in question. The way in which we do this must reflect our assessment of the level of risk arising from the particular client and the particular matter.
This client risk assessment form, combined with our CDD matter risk assessment form, will help us to determine the level of CDD we
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This Precedent letter covers disclosure obligations under CPR 31. It does not apply to proceedings subject to the disclosure pilot scheme under CPR PD 51U. For guidance on the disclosure pilot scheme, see Practice Note: Business and Property Courts—the disclosure pilot scheme. For a client letter on
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