TABLE OF CONTENTS
First AML will conduct standard due diligence if the executor or administrator is not a reporting entity. If instructed, First AML will collect, but not verify, the source of wealth/funds if the reporting entity requires enhanced due diligence to be conducted.
Please refer to the AML/CFT (Exemptions) Amendment Regulations 2021 sections 24AD and 24AE for further information.
Who do we verify?
If the executor or administrator is a reporting entity, you are exempt from conducting customer due diligence. For reporting purposes, the transaction should still be submitted via the Platform.
If the reporting entity is providing a relevant service to an executor or administrator of an estate, e.g. executor is an individual (the reporting entity is not the executor or administrator):
CDD the executor/administrator (not the Estate). Must ID&V all individuals
If non-individuals must ID&V all directors or equivalent of that entity
The executor/administrator is the customer of the reporting entity, not the estate itself.
Collect the probate/deed and its amendments (if applicable) to confirm the executor/administrator.
If no probate, First AML will collect the Will
Source of wealth/source of funds:
If executor(s) are individual(s) (not a reporting entity) a source of wealth statement is required (no evidence is required)
If executor(s) are a reporting entity, no source of wealth statement is required.