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The application of due diligence procedures entails that remittance centers monitor, and make sure that they understand, the financial transactions of customers and their real beneficiaries; and that they verify all business activities in which they engage, as well as information related to membership creation while satisfying themselves that such information is reliable and clear. The instructions require that remittance centers apply the essential due diligence procedures to all permanent and temporary customers, including real beneficiaries, and that these procedures be continuous and consistent with the degree of risks associated with the business and transactions carried out by customers as follows:
1)
Track the activities of financial transactions and their consistency with the information provided by customers.
2)
Due diligence procedures are required upon creating and strengthening the relationship when carrying out sporadic transactions whose value, individually or collectively, exceeds the declared limits. They are also required in the event of cases suspected to involve ML/TF, regardless of exemptions or transaction amount limits, or in case of doubts about the accuracy or adequacy of the information previously obtained when identifying customers.
3)
Check whether any person is acting on behalf of the customer and ensuring the legality of such practice.
4)
Determine the persons who hold ownership or control over the customer.
5)
Due diligence procedures shall be strengthened for high-risk customers possibly due to the volume or types of anticipated or actual transactions, including those that involve jurisdictions classified as high risk or those mentioned on the FATF website as being jurisdictions that do not adequately implement the recommendations related to AML/CFT, or transactions that are defined by law or applicable instructions as being a high-risk source, such as correspondent banking relationships and politically exposed persons.
6)
Simple due diligence procedures and measures shall not be acceptable in case of suspicion of ML/TF transactions.
7)
Ability to mitigate the due diligence requirements on relationships that have been classified into low risk categories according to the risk assessment carried out by the remittance center.
8)
To not permit the termination or absolute restriction of relationships with entire categories of customers aiming to avoid risk management or due to limited financial returns (profits) and without considering other risk mitigation measures for individual customers within a specific sector and dealing with risks on a case-by-case basis.
Book traversal links for 9.6: Customer Due Diligence (CDD) Measures