What has changed for those caught by the Regulations?

If your business was caught by the previous Regulations you will already have a number of relevant policies and procedures in place. To remain compliant you should revisit these and ensure that they are updated to meet the extended requirements. Key areas to consider include understanding the meaning of CDD; this being something more than simply obtaining evidence of the identity of your new clients. Procedures must now be applied to existing clients and your client portfolio will need to be risk-assessed.

You should ensure that your internal checklists are updated for the latest requirements. For example to consider whether you have met your client face to face or the client is a ‘politically exposed person’. You will need to establish policies and procedures that will determine when and how you update your CDD and how you will monitor your business relationships on an ongoing basis.

Your new policies and procedures must be communicated to your team and regular training must be provided on how to recognise and deal with transactions and other activities which may be related to money laundering or terrorist financing.