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Simplified due diligence
Standard due diligence
Enhanced due diligence
First AML will conduct Simplified Due Diligence when the customer is:
Please see the full list of qualifying entities in the AML/CFT Act Section 18(2).
First AML will collect information regarding the simplified entity and note the relevant legislation that qualifies the customer for simplified due diligence.
For a publicly listed company or company majority-owned by a publicly listed company, we will collect the following information:
‘Acting on behalf’ refers to the individual that is authorised to act on behalf of an entity for a specific Simplified Due Diligence transaction.
First AML will collect the following information as per Section 19 of the AML/CFT Act for a person acting on behalf of a customer.
First AML will obtain reliable and independent evidence to confirm the person’s authority to act on behalf of the customer.
Being able to outsource our AML compliance requirements, means our staff are not bogged down making everyone happy.
Mike Kemps, Kemps Weir Lawyers
First AML will conduct Standard Due Diligence when neither Enhanced nor Simplified Due Diligence applies.
Please see the full list of qualifying circumstances in the AML/CFT Act Section 14(1).
First AML collects the following information to verify the customer and all beneficial owner(s) of the customer as per the AML/CFT Act Section 15.
As per the AML/CFT Act Section 5(1), a beneficial owner means any individual who:
Please note the prescribed threshold is more than 25% for the definition of beneficial owner under section 5(1) of the Act. Please refer to the AML/CFT (Definitions) Regulations 2011.
First AML will electronically verify the person’s name and date of birth against reliable and independent sources. First AML will default to manual verification if electronic verification is not possible. Please see Documental Certification Standards below.
First AML will confirm the existence of a nominee director, shareholders or shares in bearer form directly with the case contact. This confirmation will be collected via email reply, text or phone call. Please refer to the AML/CFT (Requirements and Compliance) Amendment Regulations 2021 sections 11 and 12 for further information.
For overseas entities, First AML will seek to obtain copies of the relevant entity documents to confirm beneficial ownership of the entity.
Being able to outsource our AML compliance requirements, means our staff are not bogged down making everyone happy.
Mike Kemps, Kemps Weir Lawyers
– Lisle Clements, Grant Thornton
Enhanced Due Diligence is conducted whenever instructed by the Reporting Entity to do so (e.g. because the Customer is high risk), and whenever required by the AML/CFT Act, including when the customer person/entity is (but not limited to):
Please see the full list of qualifying circumstances in the AML/CFT Act Section 22.
In addition to the Standard Due Diligence verification, First AML may collect information to verify the source of funds/wealth of the customer.
First AML will collect source of funds/wealth evidence in line with our source of funds/wealth guidelines that we send to the customer.
First AML does not collect certified copies of Source of Wealth/Funds evidence.
There are two ways for a Reporting Entity to request Ongoing Customer Due Diligence (OCDD) cases. These cases must be a previously verified entity within the Reporting Entity’s own First AML database.
For individual cases, First AML will send out a new Electronic Verification Form (EIV Form) and will re-verify their details to ensure it is up to date. This will be charged at the standard individual fee.
Being able to outsource our AML compliance requirements, means our staff are not bogged down making everyone happy.
Mike Kemps, Kemps Weir Lawyers
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