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CDD Individual
Customer Due Diligence - Individual
Client Details
Company Name
*
Client Name
*
Date
Prepared by
Mak Chun Fan
Fan Wai Man
Leanne Kan
Other
File No
T06 Risk Assessment Form - Individual
Does the client meet the requirement for automatic enhanced due diligence as a result of:
Being a case identified as high risk in our firm-wide risk assessment.
Y
N
N/A
Being a politically exposed person (PEP) or a close family member or known close associate of a PEP
Y
N
N/A
Being in a business relationship or transaction (personally or through a business) with a person established in or with connections to, a high risk third country.
Y
N
N/A
Providing false or stolen ID documentation.
Y
N
N/A
A transaction being complex and unusually large or having an unusual pattern of transactions.
Y
N
N/A
The transaction/(s) having no apparent economic or legal purpose.
Y
N
N/A
**Any ‘yes’ answers will indicate a high risk client for AML purposes
No (Continue)
Yes
(High Risk)
Are any of the following risk factors present in your client?
The business relationship is conducted in unusual circumstances
Y
N
N/A
The client is involved in transactions that favour anonymity.
Y
N
NA
The client is resident in or has connections with a geographical area of high risk
Y
N
N/A
You have not met the client.
Y
N
N/A
The client receives payments from unknown or un-associated third parties.
Y
N
N/A
**Does the presence of any of these risk factors indicate a higher risk of money laundering or terrorist financing?
No (Continue)
Yes
(High Risk)
Does the individual otherwise present a higher than normal risk of money laundering or terrorist financing?
No
(Normal Risk)
Yes
(High Risk)
Enhanced due diligence to be performed where risk is assessed as high
Obtaining approval of senior management to commence or continue the relationship
Y
N
N/Y
Additional evidence to support verification of identity
Y
N
N/A
More detailed customer due diligence/ Know Your Client information to better understand the background and financial situation of the client and others party to transactions
Y
N
N/A
Additional steps to be satisfied that transactions are consistent with the purpose and intended nature of the business relationship
Y
N
N/A
Increased ongoing monitoring of the business relationship
Y
N
N/A
Increased scrutiny of transactions
Y
N
N/A
T08 Identification/ Verification of identity form – Individual
Risk assessment for client (see customer due diligence/ Know Your Client and risk assessment forms)
Low Risk
Normal Risk
High Risk
You need to obtain all the information in one section only of this form.
Government issued photo-ID
Required by: Low, Normal & High
Y
N
N/A
Comments / cross-reference to documents
Proof of home address
Required by: High risk only
Y
N
N/A
Comments / cross-reference to documents
Required: High risk only
Sanctions check (personal)
Required by: Low, Normal & High
Y
N
N/A
Comments / cross-reference to documents
OR
Government issued non-photo-ID (Should apply only in exceptional circumstances such as an overseas client with no photo ID)
Required by: Low, Normal & High
Y
N
N/A
Comments / cross-reference to documents
Proof of home address
Required by: Low, Normal & High
Y
N
N/A
Comments / cross-reference to documents
Second supporting document
Y
N
N/A
Comments / cross-reference to documents
Sanctions check (personal)
Required by: Low, Normal & High
Y
N
N/A
Comments / cross-reference to documents
OR
Certified copy of proof of individual’s identity
Required by: Low, Normal & High
Y
N
N/A
Comments / cross-reference to documents
Certified copy of proof of home address
Required by: Low, Normal & High
Y
N
N/A
Comments / cross-reference to documents
Comments / cross-reference to documents
Sanctions check (personal)
Required by: Low, Normal & High
Y
N
N/A
Satisfactory result from electronic verification
Required by: Low, Normal & High
Y
N
N/A
Comments / cross-reference to documents
Proof of home address
Required by: High risk only
Y
N
N/A
Comments / cross-reference to documents
OR
Agreement in place for reliance on third party CDD
Required by: Low, Normal & High
Y
N
N/A
Comments / cross-reference to documents
Conclusion
Satisfactory ID obtained?
Yes
No
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