When do AML KYC checks have to take place?
Section 7: Application of customer due diligence measures
(1) A relevant person must apply customer due diligence measures when he –
(a) Establishes a business relationship;
(a) Suspect money laundering or terrorist financing.
(b) Doubt the veracity or adequacy” of previous “identification or verification.
(c) And “at other times on a risk sensitive basis depending on the type of customer, business relationship, product or transaction.”
Section 8: Ongoing monitoring
(1) keeping the documents, data or information obtained for the purposes of applying customer due diligence measures up-to-date.
Section 9: Timing of verification
(a) Before the establishment of a business relationship.
So checks should be:
- Carried out during the point of initial transaction or account creation.
- Section 8 also mandates that KYC checks are necessary on an ongoing basis
- Section 9 stipulates that KYC checks must be carried out before the establishment of a business relationship
- And firms are also expected to undertake due diligence checks on a risk-sensitive basis
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192’s Anti Money Laundering Solution
Our AML solution includes an in built time and date stamp and search archive facility which ensures that our clients can prove compliance with Sections 7 & 8. Our clients can simply recall the searches that they have done and prove that searches were done at the relevant point in the customer relationship.
