Summary


This article will outline the simplified due diligence criteria under Australian, New Zealand, and United Kingdom AML legislation, as well as the information First AML collect for entities that qualify for simplified due diligence.



TABLE OF CONTENTS



Criteria


Australia


First AML will conduct Simplified Due Diligence when permitted by the Anti-Money Laundering and Counter-Terrorism Financing 2006 (AML/CTF Act), including when the customer person/entity is:

  1. A government department
  2. A publicly listed company or subsidiary of a listed parent company with >50% shareholding of the engaging private company 
  3. Companies that are licensed and regulated by a government regulator

Please see the full list of qualifying entities in the AML/CTF Rules Instrument 2007 4.3.8.



New Zealand


First AML will conduct Simplified Due Diligence when permitted by the Anti-Money Laundering and Counter Financing of Terrorism 2009 (AML/CFT Act), including when the customer person/entity is:

  1. A government department
  2. A publicly listed company or subsidiary of a listed parent company with > 50% shareholding of the engaging private company 
  3. A crown entity

Please see the full list of qualifying entities in the AML/CFT Act Section 18(2).



United Kingdom


First AML will conduct Simplified Due Diligence when permitted by the Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017, including when the person/entity is:

  1. A publicly listed company or a public administration 
  2. An individual of a low risk geographical area 
  3. A company which is listed on the regulated market


Please see the full list of qualifying entities and factors in the MLR 2017 Regulation 37(3).




What do we collect?


First AML will collect information regarding the simplified entity and note the relevant legislation that qualifies the customer for simplified due diligence. 

For a publicly listed company or company majority-owned by a publicly listed company, we will collect the following information:

  1. Company full legal name;
  2. Company number or other registration numbers;
  3. Stock ticker symbol;
  4. Registered office address and, if different, the principal place of business; and
  5. Evidence confirming the company’s publicly listed status or if this is a subsidiary, evidence of the parent/subsidiary relationship will be obtained.