AML 7.5.1 Guidance
1. AML Rule 7.5.1(1) provides examples of
Simplified CDD measures. Other measures may also be used by a Relevant Person to modify CDD in accordance with the customer risks.
Relevant Person should not use a "one size fits all" approach for all its low risk customers. Notwithstanding that the risks may be low for all such customers, the degree of CDD undertaken needs to be proportionate to the specific risks identified on a case by case basis.
Relevant Person is not required to identify or verify Beneficial Owners for retail investment funds which are widely held and for investment funds where the investor invests via pension contributions.
4. An example of circumstances where a
Relevant Person might reasonably reduce the frequency of or, as appropriate, eliminate customer identification updates would be where the money laundering risks are low and the service provided does not offer a realistic opportunity for money laundering.
5. An example of where a
Relevant Person might reasonably reduce the degree of on-going monitoring and scrutinising of transactions, based on a reasonable monetary threshold or on the nature of the transaction, would be where the transaction is a recurring, fixed contribution to a savings scheme, investment portfolio or fund or where the monetary value of the transaction is not material for money laundering purposes given the nature of the customer and the transaction type.
6. For the avoidance of doubt, a
Relevant Person should not conduct Simplified CDD where there is any suspicion of money laundering.