Our methodology has been developed in accordance with the Anti-Money Laundering and Countering Financing of Terrorism Act 2009 and Department of Internal Affairs & Financial Markets Authority (DIA & FMA) customer due diligence reference guides. We regularly update this guide in line with changes in regulations or evolving best practices (last updated in February 2022).
In this guide, “Reporting Entity” refers to you as a client of First AML and “Customer” refers to the individual or entity on whom we are conducting customer due diligence.
Our guide outlines how we collect and process information on your behalf, as First AML is a specialised CDD service provider operating as an agent under Section 34 of the AML/CFT Act.
The Reporting Entity is ultimately responsible for approving whether CDD performed by First AML on a Customer is sufficient for meeting your own internal compliance programme. In accordance with Section 56 of the AML/CFT Act, the Reporting Entity is required to maintain its own compliance programme.
First AML conducts Customer Due Diligence in line with the Act as follows:
Understand our EIV process and how we use ‘safe harbour’ procedures to verify identities of medium or low-risk individuals.
When First AML can not electronically verify an individual, we revert to acquiring certified copies of identification and a non-certified copy of a proof of address document.