The Financial Intelligence Centre (FIC) has issued a web notice regarding a communication (click here to download the full communication) intended to further clarify matters relating to business relationships with prominent, influential persons and their immediate families, CompliNEWS contributor Pam Saxby reports. Informed by a consultation process on which the FIC has now provided feedback, the communication should be read with Guidance Note 7 on implementing ‘various aspects’ of the 2001 Financial Intelligence Centre Act.
According to the communication’s introductory summary, it focuses on the money laundering risk possibly posed by these relationships, and the customer due diligence considerations to be applied in that context.
The communication deals in considerable detail with the process of determining if a prospective client, an existing client, the beneficial owner of either type of client or anyone acting on behalf of one is a domestic prominent influential person, a foreign prominent public official, their immediate family member or a known close associate.
It also suggests possible sources of information; spells out the steps to be taken in assessing the level of risk posed; cover the control measures to be imposed should that level of risk be considered high, including monitoring; and explores the potential indicators of heightening risk.