Section 15 of Part 2 of Schedule 2 to the AMLO specifies that a TCSP licensee must take additional measures or EDD to mitigate the risk of ML/TF in any situation that by its nature presents a higher risk of ML/TF.

Enhanced due diligence

High-risk situations for which EDD apply

  • customer not physically present for identification purposes
  • customer or its beneficial owner being a politically exposed person
  • corporate customer which has issued bearer shares
  • customer from or transaction connected with a jurisdiction that does not adopt or insufficiently adopts the FATF recommendations; and
  • any situation specified by the Registrar in a notice given to GRDA.

Customer not physically present

If a customer has not been physically present for identification purposes, GRDA must carry out at least one of the following measures to mitigate the risk posed:

  • further verifying the customer’s identity on the basis of documents, data or information not previously used for the purposes of verification of the customer’s identity
  • taking supplementary measures to verify information relating to the customer that has been obtained by GRDA
  • ensuring that the first payment made into the customer’s account is received from an account in the customer’s name with an authorised institution or a bank operating in an equivalent jurisdiction that has measures in place to ensure compliance with requirements similar to those imposed under Schedule 2 to the AMLO and is supervised for compliance with those requirements by a banking regulator in that jurisdiction.