Covid-19 Supplementary Anti Money Laundering Guidance – Completion of Client Due Diligence (CDD) During Urgent Work

In view of the current Covid-19 there may be circumstances in which a client requires urgent advice in a time frame that does not allow completion of client due diligence (CDD) in sufficient time.

Regulation 30(3) permits this to be completed whilst establishing the business relationship provided that the verification is completed as soon as practicable after contact is first established, and if:

(a) this is necessary not to interrupt the normal conduct of business; and

(b) there is little risk of money laundering or terrorist financing.

Although there is existing guidance, this document aims to provide further detail on the principles that underlie the guidance and how it can be applied in the current circumstances.