What we found in our 2021/22 AML monitoring reviews
We raise this finding if there is no evidence of a client risk assessment on at least one of our sampled client files. Some of the firms in this bracket will have performed a client risk assessment on some of their clients but not all.
How should you perform CDD on new clients?
Firms should perform CDD on all new clients. This means that the firm should gather information on the client to determine who the client is, what it does and who the beneficial owner is. Using this information, the firm should perform an AML risk assessment, considering those risks identified in the firm-wide risk assessment. It must then take steps to check the client is who they say they are. The amount of evidence the firm needs to gather will be determined by the AML risk profile of the client
Why is it important?
Effective CDD is your greatest defence against being used to facilitate money laundering. It improves your firm’s ability to identify money laundering risks before a business relationship commences.
Resources to support compliance
Read the report
Read our 2021/22 anti-money laundering supervision report for more detail on the results of our monitoring reviews, the outcomes of those reviews and enforcement action taken. The report also summarises all of our anti-money laundering supervisory activity during the period.