Model Compliance Programme for Accountants.doc

Include details for the enhanced additional due

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POPULATE THS SECTION. INCLUDE DETAILS FOR THE ENHANCED/ ADDITIONAL DUE DILIGENCE PROCEDURES TO BE APPLIED AND THE PROCESS ON GOING MONITORING OF THE CLIENT BASE Page | 12
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5.8 Retrospective due diligence Retrospective due diligence will be conducted for all existing clients. Where identity information on existing accounts do not meet the requirements of the AML / CTF guidelines, I/Entity XXX….DOCUMENT MANAGEMNT’S PROCEDURE FOR THE COMPLETION OF RETROSPECTIVE DUE DILIGENCE 5.9 Beneficial owners (a)The identity of any beneficial owners of any clients must be verified. (b) Original identification documents/ data must be requested. (b)Where the beneficial owner is a legal person where there is a legal arrangement, the following measures must be applied as outlined in Regulation 12 (2) of the FOR: verify that the person acting on behalf of the legal person or legal arrangement is authorised and identify and verify the identity of that person verify the legal status of the legal person or legal arrangement understand the ownership and control structure of the legal person or legal arrangement determine who are natural persons who have effective control over the legal person or legal arrangement 5.10 Third Party/ Representative Applicants (a)If the applicant for business appears to be acting as a representative of a client, the following must be applied as outlined in Regulation 13 in the FOR: Request written assurance from the applicant that the identity of the client has been recorded in accordance with appropriate customer due diligence procedures; two forms of ID are required (b) Take measures necessary to ascertain that the applicant is legally authorised to act on behalf of the client. 5.11 Politically Exposed Persons (PEPs) – local and foreign Page | 13
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(a)Politically exposed persons are defined in Regulation 20 (1) in the FOR as i. a current or former senior official in the executive, legislative, administrative or judicial branch of a foreign government, whether elected or not ii. a senior official of a major political party iii. a senior executive of a foreign government-owned commercial enterprise iv. a senior military official v. an immediate family member of a person mentioned in paragraphs (i) to (iv) meaning the spouse, parents, siblings or children of that person and the parents, siblings and additional children of the person's spouse vi. any individual publicly known or actually known to the relevant financial institution to be a close personal or professional associate of the person mentioned in paragraphs (i) to (iv) (b) Where the client or beneficial owner is determined to be a PEP, identification data as required by Section 5.3 is to be obtained. (c) Further due diligence procedures are to be conducted including determining the source of wealth and source of funds of the PEP.
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