• 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.

      October 2010

    • FC-1.3.2

      Licensees should examine, as far as reasonably possible, the background and purpose of all complex, unusual large transactions, and all unusual patterns of transactions, which have no apparent economic or lawful purpose. Where the risks of money laundering or terrorist financing are higher, licensees should conduct enhanced CDD measures, consistent with the risks identified. In particular, they should increase the degree and nature of monitoring of the business relationship, in order to determine whether those transactions or activities appear unusual or suspicious. The additional inquiries or information referred to in Paragraph FC-1.3.1 include:

      (a) Obtaining additional information on the customer (e.g. occupation, volume of assets, information available through public databases, internet, etc.) and updating more regularly the identification data of customer and beneficial owner;
      (b) Obtaining additional information on the intended nature of the business relationship;
      (c) Obtaining information on the source of funds or source of wealth of the customer;
      (d) Obtaining information on the reasons for intended or performed transactions;
      (e) Obtaining the approval of senior management to commence or continue the business relationship;
      (f) Conducting enhanced monitoring of the business relationship, by increasing the number and timing of controls applied, and selecting patterns of transactions that need further examination;
      (g) Taking specific measures to identify the source of the first payment in this account and applying RBA to ensure that there is a plausible explanation in any case where the first payment was not received from the same customer’s account;
      (h) Obtaining evidence of a person's permanent address through the use of a credit reference agency search or through independent governmental database or by home visit;
      (i) Obtaining a personal reference (e.g. by an existing customer of the licensee);
      (j) Obtaining another licensed entity's reference and contact with the concerned licensee regarding the customer;
      (k) Obtaining documentation outlining the customer's source of wealth;
      (l) Obtaining additional documentation outlining the customer's source of income; and
      (m) Obtaining additional independent verification of employment or public position held.
      January 2022
      October 2010

    • 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.

      October 2010