Summary


This article will outline the enhanced 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 enhanced due diligence.



TABLE OF CONTENTS


Criteria


Australia


Enhanced due diligence is conducted whenever instructed by the Reporting Entity to do so, (e.g. because the Customer is high risk) and whenever required by the AML/CTF Act, including when the customer person/entity is (but not limited to):

  1.  it determines that the ML/TF risk is high; or
  2. a designated service is being provided to a customer who is or who has a beneficial owner who is, a foreign politically exposed person; or
  3. a suspicion has arisen for the purposes of section 41 of the Act (suspicious matter reporting obligations); or
  4. a party to a transaction involving the reporting entity is physically present in, or is a corporation incorporated in, a prescribed foreign country




New Zealand


Enhanced Due Diligence is conducted whenever instructed by the Reporting Entity to do so (e.g. because the Customer is high risk), and whenever required by the AML/CFT Act, directors including when the customer person/entity is (but not limited to): 

  1. A trust or another vehicle holding personal assets
  2. A company with 1 or more nominee directors, or shareholders or shares in bearer form
  3. A limited partnership with nominee general partners
  4. A customer deemed by the Reporting Entity to be high risk e.g. customer has been determined to be a politically exposed person


Please see the full list of qualifying circumstances in the AML/CFT Act Section 22.



United Kingdom


Enhanced due diligence is conducted whenever instructed by the Reporting Entity to do so, and whenever required by the MLR 17, including when the customer person/entity is (but not limited to):

  1. resident in a geographical area of high risk 
  2. a legal person or arrangement that is a vehicle for holding personal assets
  3. a company with 1 or more nominee directors, or shareholders or shares in bearer form

reported to be high risk e.g. customer has been determined to be a politically exposed person


Please see the full list of qualifying circumstances in Reg 33 MLR 2017. 




First AML does not conduct Enhanced Due Diligence on companies with trust(s) in shareholding. 


If your compliance programme requires source of wealth/funds evidence to be collected under different requirements, please inform your Implementation Manager/Customer Success Manager.



What do we collect?


In addition to Standard Due Diligence verification, First AML may collect information to verify the source of funds/wealth of the Customer. The source of wealth/funds evidence will be collected for the Direct Customer.


First AML will collect source of funds/wealth evidence in line with our source of funds/wealth guidelines that we send to the Customer. Please ask your Implementation Specialist for a copy if required. 



First AML does not collect certified copies of Source of Wealth/Funds evidence. 


If you would like to know more about what is Source of Wealth and Source of Funds Evidence click here


If you would like to know more about the difference between Source of Wealth vs Source of Funds click here