Enhanced customer due diligence (ECDD) program

You must get more information from the customer or third party sources so you can do one or more of the following:

• clarify or update customer or beneficial owner information
• take reasonable measures to identify the customer’s and beneficial owners’ source of wealth and funds (‘reasonable’ means what is practical and necessary in line with your identified money laundering/terrorism financing risk)
• clarify the nature of their ongoing business with you.

You may also need to undertake a more detailed analysis of the customer’s identification (KYC) information. This might include:

• taking reasonable measures to conduct more analysis of the source of the customer’s and each beneficial owner’s wealth and funds (‘reasonable’ means what is practical and necessary in line with your identified money laundering/terrorism financing risk).

When verifying or re-verifying customer information, you must do so in accordance with Part B of your AML/CTF program, Customer identification.

• If your customer is an individual, you must verify or re-verify their full name and either their date of birth or residential address so you are satisfied they are who they claim to be.
• If your customer is a company, trust, association, partner or government body you must also verify or re-verify information.
• Verify or re-verify the information using your company’s usual customer identification procedures.
• Make sure those checks are based on reliable and independent documentation or electronic data.

In some circumstances you may need to examine and monitor the customer’s past and future transactions.

• You should try to establish the purpose and reason for transactions and monitor their types and frequencies.
• You should monitor the expected nature and levels of your customer’s transactions, including any future transactions.

You must seek approval from senior management to:

• continue a business relationship with the customer
• keep providing designated services to the customer
• process a transaction on an account.