(Guideline Chapter 5)
CDD is intended to enable GRDA to form a reasonable belief that it knows the true identity of each customer and, with an appropriate degree of confidence, knows the type of business and transactions the customer is likely to undertake. The CDD requirements are set out in Schedule 2 to the AMLO. Depending on specific circumstances, GRDA may also need to conduct additional measures referred to as enhanced customer due diligence (“EDD”) or, alternatively, may conduct simplified customer due diligence (“SDD”).
The CDD measures applicable to GRDA under section 2 of Part 2 of Schedule 2 to the AMLO are:
GRDA must apply CDD :
GRDA must complete the CDD process before establishing any business relationship or before carrying out a specified occasional transaction. Where GRDA is unable to complete the CDD process, it must not establish a business relationship or carry out any occasional transaction with that customer and should assess whether this failure provides grounds for knowledge or suspicion of ML/TF and filing a STR with the JFIU.
After 60 working days of establishment of a business relationship with a customer
After 120 working days of establishment of a business relationship with a custom
GRDA is obligated to take steps from time to time to ensure that customers’ information obtained for the purposes of complying with the requirements of sections 2 and 3 of Part 2 of Schedule 2 to the AMLO is up-to-date and relevant. GRDA policy is to undertake periodic reviews of existing records of customers and conduct review under circumstances of certain triggering events, including:
All high-risk customers should be subject to a minimum of an annual review, and more frequently if deemed necessary by GRDA, of their profile to ensure the CDD information retained remains up-to-date and relevant.