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  • FC-1 FC-1 Customer Due Diligence

    • FC-1.1 FC-1.1 General Requirements

      • Verification of Identity and Source of Funds

        • FC-1.1.1

          Conventional bank licensees must establish effective systematic internal procedures for establishing and verifying the identity of their customers and the source of their funds. Such procedures must be set out in writing and approved by the licensee's Board of Directors. They must be strictly adhered to.

        • FC-1.1.2

          Conventional bank licensees must implement the customer due diligence measures outlined in Chapters FC-1, FC-2 and FC-3 when:

          (a) establishing business relations with a new or existing customer;
          (b) a change to the signatory or beneficiary of an existing account or business relationship is made;
          (c) a significant transaction takes place;
          (d) there is a material change in the way that the bank account is operated or in the manner in which the business relationship is conducted;
          (e) customer documentation standards change substantially;
          (f) the conventional bank licensee has doubts about the veracity or adequacy of previously obtained customer due diligence information;
          (g) carrying-out one-off or occasional transactions above BD 6,000, or where several smaller transactions that appear to be linked fall above this threshold;
          (h) carrying out wire transfers irrespective of amount; or
          (i) there is a suspicion of money laundering or terrorist financing.

        • FC-1.1.3

          For the purposes of this Module, "customer" includes counterparties such as financial markets counterparties, except where financial institutions are acting as principals where simplified due diligence measures may sometimes apply. These simplified measures are set out in Section FC-1.11.

        • FC-1.1.4

          The BMA's specific minimum standards to be followed with respect to verifying customer identity and source of funds are contained in Section FC-1.2. Enhanced requirements apply under certain high-risk situations: these requirements are contained in Sections FC-1.3 to FC-1.8 inclusive. Additional requirements apply where a conventional bank licensee is relying on a professional intermediary to perform certain parts of the customer due diligence process: these are detailed in Section FC-1.9. Simplified customer due diligence measures may apply in defined circumstances: these are set out in Section FC-1.11.

      • Verification of Third Parties

        • FC-1.1.5

          Conventional bank licensees must obtain a signed statement from all new customers confirming whether or not the customer is acting on their own behalf or not. This undertaking must be obtained prior to conducting any transactions with the customer concerned.

        • FC-1.1.6

          Where a customer is acting on behalf of a third party, the conventional bank licensee must also obtain a signed statement from the third party, confirming they have given authority to the customer to act on their behalf. Where the third party is a legal person, the conventional bank licensee must have sight of the original Board resolution (or other applicable document) authorising the customer to act on the third party's behalf, and retain a certified copy.

        • FC-1.1.7

          Conventional bank licensees must establish and verify the identity of the customer and (where applicable) the party/parties on whose behalf the customer is acting, including the Beneficial Owner of the funds. Verification must take place in accordance with the requirements specified in this Chapter.

        • FC-1.1.8

          Where financial services are provided to a minor or other person lacking full legal capacity, the normal identification procedures as set out in this Chapter must be followed. In the case of minors, licensees must additionally verify the identity of the parent(s) or legal guardian(s). Where a third party on behalf of a person lacking full legal capacity wishes to open an account, the licensee must establish the identity of that third party as well as the intended account holder.

      • Anonymous and Nominee Accounts

        • FC-1.1.9

          Conventional bank licensees must not establish or keep anonymous accounts or accounts in fictitious names. Where conventional bank licensees maintain a nominee account, which is controlled by or held for the benefit of another person, the identity of that person must be disclosed to the conventional bank licensee and verified by it in accordance with the requirements specified in this Chapter.

      • Timing of Verification

        • FC-1.1.10

          Conventional bank licensees must not commence a business relationship or undertake a transaction with a customer before completion of the relevant customer due diligence measures specified in Chapters FC-1, FC-2 and FC-3. However, verification may be completed after receipt of funds in the case of non face-to-face business, or the subsequent submission of CDD documents by the customer after initial face-to face contact, providing that no disbursement of funds takes place until after the requirements of this Chapter have been fully met.

      • Incomplete Customer Due Diligence

        • FC-1.1.11

          Where a conventional bank licensee is unable to comply with the requirements specified in Chapters FC-1, FC-2 and FC-3, it must consider whether to terminate the relationship or not proceed with the transaction, and additionally, consider whether it should file a suspicious transaction report.

        • FC-1.1.12

          See also Chapter FC-5, which covers the filing of suspicious transaction reports.

    • FC-1.2 FC-1.2 Face-to-face Business

      • Natural Persons

        • FC-1.2.1

          If the customer is a natural person, conventional bank licensees must obtain and record the following information (in hard copy or electronic form), before providing financial services of any kind:

          (a) full legal name and any other names used;
          (b) full permanent address (i.e. the residential address of the customer; a post office box is insufficient);
          (c) date and place of birth;
          (d) nationality;
          (e) passport number (if the customer is a passport holder);
          (f) CPR or Iqama number (for residents of Bahrain or GCC states);
          (g) telephone/fax number and email address (where applicable);
          (h) occupation or public position held (where applicable);
          (i) employer's name and address (if self-employed, the nature of the self-employment);
          (j) type of account, and nature and volume of anticipated business dealings with the conventional bank licensee;
          (k) signature of the customer(s); and
          (l) source of funds.

        • FC-1.2.2

          See Part B, Volume 1 (Conventional Banks), for Guidance Notes on source of funds (FC-1.2.1(1)) and requirements for residents of Bahrain (FC-1.2.1(c) & (f)).

        • FC-1.2.3

          Conventional bank licensees must verify the information in Paragraph FC-1.2.1 (a) to (f) by the following methods below; at least one of the copies of the identification documents mentioned in (a) and (b) below must include a clear photograph of the customer:

          (a) confirmation of the date of birth and legal name, by taking a copy of a current valid official original identification document (e.g. birth certificate, passport, CPR or Iqama);
          (b) confirmation of the permanent residential address by taking a copy of a recent utility bill, bank statement or similar statement from another licensee or financial institution, or some form of official correspondence or official documentation card, such as CPR, from a public/governmental authority, or a tenancy agreement or record of home visit by an official of the conventional bank licensee; and
          (c) where appropriate, direct contact with the customer by phone, letter or email to confirm relevant information, such as residential address information.

        • FC-1.2.4

          Any document copied for the purpose of identification verification must be an original. An authorised official of the licensee must certify the copy, by writing on it the words 'original sighted', together with the date and his signature. Equivalent measures must be taken for electronic copies.

        • FC-1.2.5

          Identity documents which are not obtained by an authorised official of the licensee in original form (e.g. due to a customer sending a copy by post following an initial meeting) must instead be certified (as per FC-1.2.4) by one of the following from a GCC or FATF member state:

          (a) a lawyer;
          (b) a notary;
          (c) a chartered/certified accountant;
          (d) an official of a government ministry;
          (e) an official of an embassy or consulate; or
          (f) an official of another licensed financial institution or of an associate company of the licensee.

        • FC-1.2.6

          The individual making the certification under FC-1.2.5 must give clear contact details (e.g. by attaching a business card or company stamp). The conventional bank licensee must verify the identity of the person providing the certification through checking membership of a professional organisation (for lawyers or accountants), or through checking against databases/websites, or by direct phone or email contact.

      • Legal Entities or Legal Arrangements (such as trusts)

        • FC-1.2.7

          If the customer is a legal entity or a legal arrangement such as a trust, the conventional bank licensee must obtain and record the following information from original identification documents, databases or websites, in hard copy or electronic form, to verify the customer's legal existence and structure:

          (a) the entity's full name and other trading names used;
          (b) registration number (or equivalent);
          (c) legal form;
          (d) registered address and trading address (where applicable);
          (e) type of business activity;
          (f) date and place of incorporation or establishment;
          (g) telephone, fax number and email address;
          (h) regulatory body or listing body (for regulated activities such as financial services and listed companies);
          (i) name of external auditor (where applicable);
          (j) type of account, and nature and volume of anticipated business
          dealings with the conventional bank licensee; and
          (k) source of funds.

        • FC-1.2.8

          The information provided under FC-1.2.7 must be verified by obtaining certified copies of the following documents, as applicable (depending on the legal form of the entity):

          (a) certificate of incorporation and/or certificate of commercial registration or trust deed;
          (b) memorandum of association;
          (c) articles of association;
          (d) partnership agreement;
          (e) Board resolution seeking the banking services (only necessary in the case of private or unlisted companies);
          (f) identification documentation of the authorised signatories to the account (certification not necessary for listed companies);
          (g) copy of the latest financial report and accounts, audited where possible (audited copies do not need to be certified); and
          (h) list of authorised signatories of the company for the account and a Board resolution (or other applicable document) authorising the named signatories or their agent to operate the account (resolution only necessary for private or unlisted companies).

        • FC-1.2.9

          Documents obtained to satisfy the requirements in FC-1.2.8 above must be certified in the manner specified in FC-1.2.4 to FC-1.2.6.

        • FC-1.2.10

          The documentary requirements in FC-1.2.8 above do not apply in the case of listed companies: see Section FC-1.11 below. Also, the documents listed in FC-1.2.8 above are not exhaustive: for customers from overseas jurisdictions, documents of an equivalent nature may be produced as satisfactory evidence of a customer's identity.

        • FC-1.2.11

          Conventional bank licensees must also obtain and document the following due diligence information. These due diligence requirements must be incorporated in the licensee's new business procedures:

          (a) enquire as to the structure of the legal entity or trust sufficient to determine and verify the identity of the ultimate beneficial owner of the funds, the ultimate provider of funds (if different), and the ultimate controller of the funds (if different);
          (b) ascertain whether the legal entity has been or is in the process of being wound up, dissolved, struck off or terminated;
          (c) obtain the names, country of residence and nationality of Directors or partners (only necessary for private or unlisted companies);
          (d) require, through new customer documentation or other transparent means, updates on significant changes to corporate ownership and/or legal structure;
          (e) obtain and verify the identity of shareholders holding 20% or more of the issued capital (where applicable). The requirement to verify the identity of these shareholders does not apply in the case of listed companies;
          (f) in the case of trusts or similar arrangements, establish the identity of the settlor(s), trustee(s), and beneficiaries (including making such reasonable enquiries as to ascertain the identity of any other potential beneficiary, in addition to the named beneficiaries of the trust); and
          (g) where a licensee has reasonable grounds for questioning the authenticity of the information supplied by a customer, conduct additional due diligence to confirm the above information.

        • FC-1.2.12

          For the purposes of Paragraph FC-1.2.11, acceptable means of undertaking such due diligence might include taking bank references; visiting or contacting the company by telephone; undertaking a company search or other commercial enquiries; accessing public and private databases (such as stock exchange lists); making enquiries through a business information service or credit bureau; confirming a company's status with an appropriate legal or accounting firm; or undertaking other enquiries that are commercially reasonable.

    • FC-1.3 FC-1.3 Enhanced Customer Due Diligence: General Requirements

      • FC-1.3.1

        Enhanced customer due diligence must be performed on those customers identified as having a higher risk profile, and additional inquiries made or information obtained in respect of those customers.

      • FC-1.3.2

        The additional information referred to in Paragraph FC-1.3.1 might include documents (either in hard copy or electronic format) relating to the following:

        (a) evidence of a person's permanent address through the use of a credit reference agency search or through independent verification by home visit;
        (b) a personal reference (e.g. by an existing customer of the conventional bank licensee);
        (c) another licensed entity's reference and contact with the concerned licensee regarding the customer;
        (d) documentation outlining the customer's source of wealth;
        (e) documentation outlining the customer's source of income; and
        (f) independent verification of employment, or public position held.

      • FC-1.3.3

        In addition to the general rule contained in Paragraph FC-1.3.1 above, special care is required in the circumstances specified in Sections FC-1.4 to FC-1.9 inclusive.

    • FC-1.4 FC-1.4 Enhanced Customer Due Diligence: Non face-to-face Business and New Technologies

      • FC-1.4.1

        Conventional bank licensees must establish specific procedures for verifying customer identity where no face-to-face contact takes place.

      • FC-1.4.2

        Where no face-to-face contact takes place, conventional bank licensees must take additional measures (to those specified in Section FC-1.2), in order to mitigate the potentially higher risk associated with such business. In particular, conventional bank licensees must take measures:

        (a) to ensure that the customer is the person they claim to be; and
        (b) to ensure that the address provided is genuinely the customer's.

      • FC-1.4.3

        There are a number of checks that can provide a conventional bank licensee with a reasonable degree of assurance as to the authenticity of the applicant. They include:

        (a) telephone contact with the applicant on an independently verified home or business number;
        (b) with the customer's consent, contacting an employer to confirm employment, via phone through a listed number or in writing; and
        (c) salary details appearing on recent bank statements.

      • FC-1.4.4

        Financial services provided via post, telephone or internet pose greater challenges for customer identification and AML/CFT purposes. Conventional bank licensees must establish procedures to prevent the misuse of technological developments in money laundering or terrorist financing schemes. Specifically, banks which provide significant electronic and internet banking services to their customers, should connect a programme to such systems to highlight all unusual transactions so as to enable the concerned bank to report such transactions. Conventional bank licensees must also ensure that they comply with any e-commerce laws and/or BMA regulations issued from time to time.

    • FC-1.5 FC-1.5 Enhanced Customer Due Diligence: Politically Exposed Persons ("PEPs")

      • FC-1.5.1

        Conventional bank licensees must have appropriate risk management systems to determine whether a customer is a Politically Exposed Person ('PEP'), both at the time of establishing business relations and thereafter on a periodic basis. Licensees must utilize publicly available databases and information to establish whether a customer is a PEP.

      • FC-1.5.2

        Conventional bank licensees must establish a client acceptance policy with regard to PEPs, taking into account the reputational and other risks involved. Senior management approval must be obtained before a PEP is accepted as a customer.

      • FC-1.5.3

        Where an existing customer is a PEP, or subsequently becomes a PEP, enhanced monitoring and customer due diligence measures must include:

        (a) analysis of complex financial structures, including trusts, foundations or international business corporations;
        (b) a written record in the customer file to establish that reasonable measures have been taken to establish both the source of wealth and the source of funds;
        (c) development of a profile of anticipated customer activity, to be used in on-going monitoring;
        (d) approval of senior management for allowing the customer relationship to continue; and
        (e) ongoing account monitoring of the PEP's account by senior management (such as the MLRO).

      • FC-1.5.4

        "Politically Exposed Persons" means individuals who are, or have been, entrusted with prominent public functions in Bahrain or a foreign country, such as Heads of State or government, senior politicians, senior government, judicial or military officials, senior executives of state owned corporations or important political party officials. Business relationships with family members or close associates of PEPs involve reputational risks similar to PEPs themselves. The definition is not intended to cover middle-ranking or more junior officials in the foregoing categories. Bahraini PEPs would include all Ministers, all MPs, and all Ministry officials with the rank of Undersecretary or above.

    • FC-1.6 FC-1.6 Enhanced Due Diligence: Charities, Clubs and Other Societies

      • FC-1.6.1

        Financial services must not be provided to charitable funds and religious, sporting, social, cooperative and professional societies, until an original certificate authenticated by the relevant Ministry confirming the identities of those purporting to act on their behalf (and authorising them to obtain the said service) has been obtained. For Clubs and Societies registered with the General Organisation for Youth and Sports (GOYS), conventional bank licensees must contact GOYS to clarify whether the account may be opened in accordance with the rules of GOYS.

      • FC-1.6.2

        Conventional bank licensees are reminded that clubs and societies registered with GOYS may only have one account with banks in Bahrain.

      • FC-1.6.3

        Charities should be subject to enhanced transaction monitoring by banks. Conventional bank licensees should develop a profile of anticipated account activity (in terms of payee countries and recipient organisations in particular).

      • FC-1.6.4

        Conventional bank licensees must report all payments and transfers of BD 3,000 (or equivalent in foreign currencies) and above, from accounts held by charities registered in Bahrain. The report must be submitted to the BMA's Compliance Unit (see FC-5.3 for contact address), giving details of the amount transferred, account name, number and beneficiary name account and bank details. Conventional bank licensees must ensure that such transfers are in accordance with the spending plans of the charity (in terms of amount, recipient and country).

    • FC-1.7 FC-1.7 Enhanced Due Diligence: "Pooled Funds"

      • FC-1.7.1

        Where conventional bank licensees receive pooled funds managed by professional intermediaries (such as investment and pension fund managers, stockbrokers and lawyers or authorised money transferors), they must apply CDD measures contained in Section FC-1.9 to the professional intermediary. In addition, conventional bank licensees must verify the identity of the beneficial owners of the funds where required as shown in Paragraphs FC-1.7.2 or FC-1.7.3 below.

      • FC-1.7.2

        Where funds pooled in an account are not co-mingled (i.e. where there are "sub-accounts" attributable to each beneficiary), all beneficial owners must be identified by the conventional bank licensee, and their identity verified in accordance with the requirements in Section FC-1.2.

      • FC-1.7.3

        For accounts held by intermediaries resident in Bahrain, where such funds are co-mingled, the conventional bank licensee must make a reasonable effort (in the context of the nature and amount of the funds received) to look beyond the intermediary and determine the identity of the beneficial owners or underlying clients, particularly where funds are banked and then transferred onward to other financial institutions (e.g. in the case of accounts held on behalf of authorised money transferors). Where, however, the intermediary is subject to equivalent regulatory and money laundering regulation and procedures (and, in particular, is subject to the same due diligence standards in respect of its client base) the BMA will not insist upon all beneficial owners being identified provided the bank has undertaken reasonable measures to determine that the intermediary has engaged in a sound customer due diligence process, consistent with the requirements in Section FC-1.8.

      • FC-1.7.4

        For accounts held by intermediaries from foreign jurisdictions, the intermediary must be subject to requirements to combat money laundering and terrorist financing consistent with the FATF 49 Recommendations and the intermediary must be supervised for compliance with those requirements. The bank must obtain documentary evidence to support the case for not carrying out customer due diligence measures beyond identifying the intermediary. The bank must satisfy itself that the intermediary has identified the underlying beneficiaries and has the systems and controls to allocate the assets in the pooled accounts to the relevant beneficiaries. The due diligence process contained in Section FC-1.8 must be followed.

      • FC-1.7.5

        Where the intermediary is not empowered to provide the required information on beneficial owners (e.g. lawyers bound by professional confidentiality rules) or where the intermediary is not subject to the same due diligence standards referred to above, a bank must not permit the intermediary to open an account or allow the account to continue to operate, unless specific permission has been obtained in writing from the BMA.

    • FC-1.8 FC-1.8 Enhanced Due Diligence for Correspondent Banking Relationships

      • FC-1.8.1

        The customer due diligence measures outlined under Section FC-1.2 must be carried out in the normal way on the respondent bank. Conventional bank licensees which intend to act as correspondent banks must gather sufficient information (e.g. through a questionnaire) about their respondent banks to understand the nature of the respondent's business. Factors to consider to provide assurance that satisfactory measures are in place at the respondent bank include:

        a) Information about the respondent bank's ownership structure and management;
        b) Major business activities of the respondent and its location (i.e. whether it is located in a FATF compliant jurisdiction) as well as the location of its parent (where applicable);
        c) Where the customers of the respondent bank are located;
        d) The respondent's AML/CFT controls;
        e) The purpose for which the account will be opened;
        f) Confirmation that the respondent bank has verified the identity of any third party entities that will have direct access to the correspondent banking services without reference to the respondent bank (e.g. in the case of "payable through" accounts);
        g) The extent to which the respondent bank performs ongoing due diligence on customers with direct access to the account, and the condition of bank regulation and supervision in the respondent's country (e.g. from published FATF reports). Banks should take into account the country where the respondent bank is located and whether that country abides by the FATF 40+ 9 Recommendations when establishing correspondent relationships with foreign banks. Banks should obtain where possible copies of the relevant laws and regulations concerning AML/CFT and satisfy themselves that respondent banks have effective customer due diligence measures consistent with the FATF 40+ 9 Recommendations;
        h) Confirmation that the respondent bank is able to provide relevant customer identification data on request to the correspondent bank; and
        i) Whether the respondent bank been subject to a money laundering or terrorist financing investigation.

      • FC-1.8.2

        Conventional bank licensees must implement the following additional measures, prior to opening a correspondent banking relationship:

        a) Complete a signed statement that outlines the respective responsibilities of each institution in relation to money laundering detection and monitoring responsibilities; and
        b) Ensure that the correspondent banking relationship has the approval of senior management.

      • FC-1.8.3

        Conventional bank licensees must refuse to enter into or continue a correspondent banking relationship with a bank incorporated in a jurisdiction in which it has no physical presence and which is unaffiliated with a regulated financial group (i.e. "shell banks", see Section FC-1.10). Banks must pay particular attention when entering into or continuing relationships with respondent banks located in jurisdictions that have poor KYC standards or have been identified by the FATF as being "non-cooperative" in the fight against money laundering/terrorist financing.

    • FC-1.9 FC-1.9 Introduced Business from Professional Intermediaries

      • FC-1.9.1

        A conventional bank licensee may only accept customers introduced to it by other financial institutions or intermediaries, if it has satisfied itself that the financial institution or intermediary concerned is subject to FATF-equivalent customer due diligence measures. Where conventional bank licensees delegate part of the customer due diligence measures to another financial institution or intermediary, the responsibility for meeting the requirements of Chapters FC-1 and FC-2 remains with the conventional bank licensee, not the third party.

      • FC-1.9.2

        Conventional bank licensees may only accept introduced business if all of the following conditions are satisfied:

        (a) the customer due diligence measures applied by the introducer are consistent with those required by the FATF 40 + 9 Recommendations;
        (b) a formal agreement is in place defining the respective roles of the licensee and the introducer in relation to customer due diligence measures. The agreement must specify that the customer due diligence measures of the introducer will comply with the FATF 40 + 9 Recommendations;
        (c) the introducer is able to provide all relevant data pertaining to the customer's identity, the identity of the customer and beneficial owner of the funds and, where applicable, the party/parties on whose behalf the customer is acting; also, the introducer has confirmed that the licensee will be allowed to verify the customer due diligence measures undertaken by the introducer at any stage; and
        (d) written confirmation is provided by the introducer confirming that all customer due diligence measures required by the FATF 40 + 9 Recommendations have been followed and the customer's identity established and verified. In addition, the confirmation must state that any identification documents or other customer due diligence material can be accessed by the conventional bank licensee and that these documents will be kept for at least five years after the business relationship has ended.

      • FC-1.9.3

        The conventional bank licensee must perform periodic reviews ensuring that any introducer on which it relies is in compliance with the FATF 40 + 9 Recommendations. Where the introducer is resident in another jurisdiction, the conventional bank licensee must also perform periodic reviews to verify whether the jurisdiction is in compliance with the FATF 40 + 9 Recommendations.

      • FC-1.9.4

        Should the conventional bank licensee not be satisfied that the introducer is in compliance with the requirements of the FATF 40 + 9 Recommendations, the licensee must conduct its own customer due diligence on introduced business, or not accept further introductions, or discontinue the business relationship with the introducer.

    • FC-1.10 FC-1.10 Shell Banks

      • FC-1.10.1

        Conventional bank licensees must not establish business relations with banks, which have no physical presence or "mind and management" in the jurisdiction in which they are licensed ("shell banks"). Banks must not knowingly establish relations with banks that have relations with shell banks.

      • FC-1.10.2

        Conventional bank licensees must make a suspicious transaction report to the Anti-Money Laundering Unit and the Compliance Unit if they are approached by a shell bank or an institution they suspect of being a shell bank.

    • FC-1.11 FC-1.11 Simplified Customer Due Diligence

      • FC-1.11.1

        Conventional bank licensees may apply simplified customer due diligence measures, as described in Paragraphs FC-1.11.2 to FC-1.11.8, if:

        (a) the customer is the Bahrain Monetary Agency ('BMA'), the Bahrain Stock Exchange ('BSE') or a licensee of the BMA;
        (b) the customer is a Ministry of a Gulf Cooperation Council ('GCC') or Financial Action Task Force ('FATF') member state government, a company in which a GCC or FATF government is a majority shareholder, or a company established by decree in the GCC;
        (c) the customer is a company listed on a GCC or FATF member state stock exchange with equivalent disclosure standards to those of the BSE;
        (d) the customer is a financial institution whose entire operations are subject to AML/CFT requirements consistent with the FATF Recommendations / Special Recommendations and it is supervised by a financial services supervisor in a FATF or GCC member state for compliance with those requirements;
        (e) the customer is a financial institution which is a subsidiary of a financial institution located in a FATF or GCC member state, and the AML/CFT requirements applied to its parent also apply to the subsidiary; or
        (f) the customer is a borrower in a syndicated transaction where the agent bank is a financial institution whose entire operations are subject to AML/CFT requirements consistent with the FATF Recommendations / Special Recommendations and it is supervised by a financial services supervisor in a FATF or GCC member state for compliance with those requirements;
        (g) the transaction is a one-off or occasional transaction not exceeding BD 6,000 (or equivalent in other currencies), or one of a number of transactions which are related and, when taken together, do not exceed BD 6,000 per year (or equivalent in other currencies).

      • FC-1.11.2

        For customers falling under categories a–f specified in Paragraph FC-1.11.1, the information required under Paragraph FC-1.2.1 (for natural persons) or FC-1.2.7 (for legal entities or legal arrangements such as trusts) must be obtained. However, the verification and certification requirements in Paragraphs FC-1.2.3 and FC-1.2.8, and the due diligence requirements in Paragraph FC-1.2.11, may be dispensed with. Where the account is a correspondent banking relationship, enhanced due diligence applies. Refer to Section FC-1.8.

      • FC-1.11.3

        For customers falling under category (g) in paragraph FC-1.11.1, the customer's name and contact information must be recorded. However, the verification, certification and due diligence requirements in Paragraphs FC-1.2.3, FC-1.2.8 and FC-1.2.11 may be dispensed with. As a matter of prudence, it is recommended that identification documentation is checked by the Conventional Bank Licensee. Conventional bank licensees may, of course, continue to apply the verification, certification and due diligence requirements mentioned in Paragraph FC-1.11.2 for their own purposes.

      • FC-1.11.4

        Conventional bank licensees wishing to apply simplified due diligence measures as allowed for under Paragraph FC-1.11.1 must retain documentary evidence supporting their categorisation of the customer.

      • FC-1.11.5

        Examples of such documentary evidence may include a printout from a regulator's website, confirming the licensed status of an institution, and internal papers attesting to a review of the AML/CFT measures applied in a jurisdiction.

      • FC-1.11.6

        Conventional bank licensees may use authenticated SWIFT messages as a basis for confirmation of the identity of a financial institution under FC-1.11.1 (d) and (e) where it is dealing as principal. For customers coming under Paragraph FC-1.11.1 (d) and (e), conventional bank licensees must also obtain and retain a written statement from the parent institution of the subsidiary concerned, confirming that the subsidiary is subject to the same AML/CFT measures as its parent.

      • FC-1.11.7

        Simplified customer due diligence measures must not be applied where a conventional bank licensee knows, suspects, or has reason to suspect, that the applicant is engaged in money laundering or terrorism financing or that the transaction is carried out on behalf of another person engaged in money laundering or terrorism financing.

      • FC-1.11.8

        Simplified customer due diligence measures must not be applied where a conventional bank licensee knows, suspects, or has reason to suspect, that transactions are linked, such that they exceed the threshold specified in Paragraph FC-1.11.1(g).