AML 7.6.1 Guidance
1. In complying with Rule 7.6.1(1)(d), a
Relevant Person should undertake a periodic review to ensure that non-static customer identity documentation is accurate and up-to-date. Examples of non-static identity documentation include passport number and residential/business address and, for a legal person, its share register or list of partners.
Relevant Person should undertake a review under Rule 7.6.1(1)(d) and (e), both periodically and at other appropriate times such as when:
Relevant Person changes its CDD documentation requirements;
b. an unusual transaction with the customer is expected to take place;
c. there is a material change in the business relationship with the customer; or
d. there is a material change in the nature or ownership of the customer.
3. The degree of the on-going due diligence to be undertaken will depend on the customer risk assessment carried out under Rule 6.1.1.
Relevant Person's transaction monitoring policies, procedures, systems and controls, which may be implemented by manual or automated systems, or a combination thereof, are one of the most important aspects of effective CDD. Whether a Relevant Person should undertake the monitoring by means of a manual or computerised system (or both) will depend on a number of factors, including:
a. the size and nature of the
Relevant Person's business and customer base; and
b. the complexity and volume of customer transactions.