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AML: Client Take On - Risk Based CDD

  • Identifying, from the Money Laundering Regulations 2007, the new statutory obligations for the generality of the CDD requirements
  • Considering the relevant JMLSG Guidance on the obligations identified out of the above
  • Probing the consequences of making statutory the obligations that were previously best practice, including:
    • Researching, structuring and documenting a risk based assessment
    • Application of new due diligence obligations generally
    • New statutory definitions of PEPs, beneficial owners and other higher risk relationships
    • Enhanced due diligence
    • Ongoing monitoring, including as part of the enhanced due diligence obligation
  • Issues arising from the day-to-day application of CDD processes
  • Other issues identified for consideration by delegates in the workshop

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