Financial Crime World

Customer Due Diligence (CDD) Measures for Anti-Money Laundering and Combating the Financing of Terrorism (AML/CFT)

Introduction

This article outlines key measures for conducting customer due diligence as required under AML/CFT laws. It provides a concise summary of the essential points for reporting entities to ensure compliance with regulations.

Article 19: Measures for Customer Due Diligence for Representatives

Reporting entities must conduct CDD on individuals who represent customers in transactions, ensuring that they can verify their identity and that of the customer they represent. This includes checking identification documents and confirming the representative’s authority to act on behalf of the customer.

  • Verify representative’s identity
  • Check identification documents
  • Confirm authority to act on behalf of the customer

Article 20: Measures for Customer Due Diligence for Politically Exposed Persons (PEPs)

Reporting entities must conduct CDD on customers who are PEPs, in addition to general AML/CFT requirements. This includes:

Enhanced Due Diligence for High-Risk Individuals

  • Determine if the customer is a high-risk individual
  • Conduct enhanced due diligence

Identifying and Reporting Suspicious Transactions

  • Identify the PEP and their relationship with the reporting entity
  • Report suspected transactions related to money laundering or terrorism financing to the relevant authorities

Ongoing Monitoring of PEPs

  • Conduct ongoing monitoring of the PEP’s activities

Article 21: Measures for Customer Due Diligence for Legal Entities

Reporting entities must conduct CDD on customers who are legal entities, including:

Verifying Entity Identity and Documentation

  • Verify the entity’s identity
  • Check documentation related to its creation and operation

Identifying Beneficial Owners

  • Identify beneficial owners (individuals with significant control or interest in the entity)
  • Verify their identities

Determining Entity Structure and Ownership

  • Determine the entity’s structure and ownership
  • Identify individuals with significant control or interest in the entity

Key aspects of CDD for legal entities include:

  • Verifying documentation related to the entity’s creation, such as certificates of incorporation or partnership documents
  • Identifying beneficial owners and verifying their identities
  • Determining the entity’s structure and ownership, including identifying individuals with significant control or interest in the entity