Handbook on Anti-Money Laundering and Combating the Financing of Terrorism for Nonbank Financial Institutions by Asian Development Bank;

Author:Asian Development Bank;
Language: eng
Format: epub
Publisher: Asian Development Bank Institute
Published: 2018-08-15T00:00:00+00:00

Updating knowledge of the customer

The expected activity, based on information obtained from the customer when the account and/or relationship was established, of all customer accounts must be kept up to date by all relevant staff, with particular reference to

• documenting customer transactions,

• documenting events that are considered important to give the NBFI a better understanding of the customer and their activities,

• large cash transactions being undertaken,

• providing the compliance officer with customer and CDD information, and

• making sure that the NBFI knows the identity of the beneficial owner of funds.

Documentation to be held in customer files should include notes and reports containing details of

• the customer, reason for opening the account(s) with the NBFI, any beneficial owner, third party, etc.; and

• the nature of the customer’s business, including seasonal trends, expected volume of transactions, etc.

In ensuring that customer information is kept up to date, a file note (including call reports) as and when appropriate must be completed by staff. Such notes should record meetings and telephone discussions with the customer.

The following specific trigger events will give rise to a full review of the CDD information and documentation for a corporate or business client:

• change of ownership,

• change in the nature of the business,

• significant increase in turnover, and

• noticeable changes in the nature of transactions or activity(ies).

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