Ongoing CDD
Changes included in the updated AML/CFT Programme Guideline affect you and your ongoing customer due diligence. Key takeaways are:
You will need to consider updating customer due diligence information when there is a risk-based reason for doing so, this is known as a trigger event.
It is not consider necessary that you regularly re-verify a person’s biographical information if you have verified it previously unless there are concerns regarding the person’s identity.
The expiration of identity documents does not in itself trigger a requirement to update a customer’s information.
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