Client due diligence process workflow
Published by a LexisNexis Practice Compliance expert
Last updated on 20/08/2020

The following Practice Compliance precedent provides comprehensive and up to date legal information covering:

  • Client due diligence process workflow

Client due diligence process workflow

This Precedent Flowchart can be issued to staff to explain your process for conducting client due diligence (CDD) on new and existing clients. It is intended to help you comply with the CDD requirements of the Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017, as amended. This workflow dovetails with the New client, New matter, CDD client risk assessment and CDD matter risk assessment form Precedents in the Client and matter inception subtopic.

Precedents referred to

This workflow refers to the following Precedents:

  1. CDD client risk assessment form—law firms

  2. CDD matter risk assessment form—law firms

  3. New client form

  4. New matter form

  5. Client due diligence matrix

  6. File information form

  7. Matter project plan

  8. AML and counter-terrorist financing policy—law firms

Other Precedents that may be of use include:

  1. Establishing the source of funds and source of wealth—guidance table for staff

  2. Source of funds/wealth statement

  3. Source of funds/wealth investigation record

  4. Third party funds investigation record

  5. Table of high-risk third countries

  6. High-risk ongoing monitoring form

  7. Guide to beneficial ownership for law firm staff

  8. CDD beneficial ownership discrepancy report form

  9. Money Laundering Regulations 2017—third party reliance arrangement

  10. Client and matter inception procedure

When is CDD required?

You must carry out CDD where the anti-money laundering (AML) and counter-terrorist financing (CTF) regime applies. Some firms will choose to carry out CDD for all clients and all matters

Related documents:
Key definition:
Due diligence definition
What does Due diligence mean?

Due diligence means that all reasonable precautions were taken and all due diligence was exercised to avoid the commission of the offence. This requires the defendant to produce evidence of the system and procedures it has devised in an effort to avoid unfair practices.

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