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Customer due diligence

Customer due diligence means obtaining a customer’s:

• name

• photograph on an official document which confirms their identity

• residential address and date of birth

The firm needs to identify the ‘beneficial owner’ in certain situations. This may be because someone else is acting on behalf of another person in a particular transaction, or it may be because the firm needs to establish the ownership structure of a company, partnership or trust.

When the firm needs to apply customer due diligence measures

• when we establish a business relationship with a customer

• when we suspect money laundering or terrorist financing

• when we have doubts about a customer’s identification information that we obtained previously

• when it’s necessary for existing customers - for example if their circumstances change

• if a customer is not a high value dealer and carry out an ‘occasional transaction’ worth €15,000 or more

• if a customer is a high value dealer and

• make a payment to a supplier worth €10,000 or more

• carry out an ‘occasional transaction’ worth €10,000 or more

The changing circumstances of our customers

We need to keep up-to-date information on our customers so that we can:

• amend our risk assessment of a particular customer if their circumstances change

• carry out further due diligence measures if necessary

Changes of circumstance may include:

• a big change in the level or type of business activity

• a change in the ownership structure of a business

When to apply customer due diligence for occasional transactions

We must carry out customer due diligence measures when our business carries out occasional transactions. These are transactions that aren’t carried out within an ongoing business relationship where the value is:

• €15,000 or more if the clients is not a high value dealer (or the equivalent in other currencies)

• €10,000 or more if the client is a high value dealer (or the equivalent in other currencies)

This applies whether it’s a single transaction or linked transactions.

(Linked transactions are individual transactions of less than €15,000 (or €10,000 for high value dealers) that have been deliberately broken down into separate, smaller transactions to avoid customer due diligence checks.)

Record keeping requirements

We need to keep a record of all customer due diligence measures that you carry out, including:

• customer identification documents that you’ve obtained

• risk assessments

• your policies, controls and procedures

• training records

By keeping comprehensive records the firm will be able to show that the business has complied with the Money Laundering Regulations. This is crucial to protect the business if there’s an investigation into one of our customers.

The types of record we keep

• daily records of transactions

• receipts

• cheques

• customer correspondence

The formats that you can keep your records in are:

• originals

• photocopies

• scanned

• computerised or electronic

We must keep your records for five years beginning from:

• the date a business relationship ends

• the date a transaction is completed