Keeping CDD information up-to-date will enable the organisation to assess whether the proposed business relationship, transaction or instructions are in line with the organisation’s expectations.
This process is known as “ongoing monitoring”.
Key points for support staff
Support staff may get involved in obtaining company search documentation or asking clients to bring in the requisite documentation.
Clients may ask you to explain why the documentation is required, so it is important that you understand why it is being sought.
Support staff may also play a valuable role in double-checking that the identification evidence requested has actually been received and sent to the record keeping department.
The source of funds
In most instances, there is no direct obligation to know the source of our client’s funds. That is, there is no requirement to ask the client how they came to have the funds to purchase a particular asset. However, everyone concerned in the matter should be alert to any possibility that the funds do not arise from a legitimate source
Note: When funds sourced from a high-risk territory are going to be used, it is likely to be appropriate to obtain more information before proceeding.
Support staff can play a key role in this process by being aware of these details and checking that when the funds are received, they actually come from the specified account.
If they do not, this should be brought to the attention of the appropriate person without delay. There could be a perfectly innocent explanation, but it is something that needs to be checked out.
Well done! You have completed Module 3 and should now have a better understanding of how to appropriately conduct CDD.
Next, we will look at some of the circumstances and situations where it might be reasonable to suspect money laundering and what to do about it.
You will now complete a scenario based quiz to test what you have learned so far
You are not marked on this scenario quiz