It is necessary to consider the different ML/TF risks that the full range of your customers pose to your business when you formulate your customer identification procedures. Most customers using the designated services you provide will be legitimate; however your systems and procedures need to be alert and responsive to instances where a customer's background places them into a category of a higher risk customer. For this reason it is a legal requirement to correctly identify a customer before providing the customer with a designated service, so that you can begin assessing the relevant risks the customer may present. The AML/CTF Rules will detail any special conditions where this requirement does not apply. Failure to correctly identify and verify the customer at the outset may prevent any effective ongoing customer due diligence activity.

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