8.3. Lower-risk situations for simplified customer due diligence measures

Lower risk factors

Financial institutions may be allowed to apply simplified CDD measures

Provided there has been an adequate analysis of the risk

(a) Customer

They have effectively implemented AML/CFT requirements

For the following types of customers

They are being effectively supervised or monitored

Financial institutions and DNFBPs where they are subject to AML/CFT requirements

Public companies listed on a stock exchange and subject to disclosure requirements

If these requirements can ensure adequate transparence of beneficial ownership

Public administrators or enterprises

(c) Country

A country was identified by credible sources as

Having effective AML/CFT systems

Having low level of criminal activity, e.g. corruption

It was identified by a mutual evaluation

E.g. a single premium is less than USD/EUR 2,500; an annual premium is less than USD/EUR 1,000

(b) Product, service, transaction, delivery channel

Life insurance policies where the premium is low

There is no early surrender option

Insurance policies for pension schemes

The policy cannot be used as collateral

A pension, superannuation, etc. that provides retirement benefits to employees

Contributions are made by way of deduction from wages

The scheme rules do not permit the assignment of a member’s interest

Appropriately defined and limited financial products or services provided to certain types of customers, so as to increase accesses for financial inclusion purposes

8.4. Enhanced customer due diligence measures

Financial institutions should examine

As far as possible

Background

Purpose

Of

Complex transactions

Unusual large transactions

Unusual patterns of transactions

Where the risks of money laundering and terrorist financing are higher

The measures should be consistent with the risks identified

Occupation

Information from public databases

E.g.

Enhanced CDD measures

Obtaining

The customer

The source of funds or wealth of the customer

Volume of assets

The intended nature of the business relationship

Additional information on

Information on

Approval of senior management to commence or continue the business relationship

The reasons for intended or performed transactions

Updating more regularly the identification data of the customer and beneficial owner

Conducting enhanced monitoring of the business relationship