As in accordance with Circular 219 – ESAs Guidelines on anti-money laundering and countering the financing of
terrorism – ‘The Risk Factors Guidelines’Use of Affiliates, when CIFs process clients for anti-money laundering, and counter terrorist financing, they must classify then using a risk-based approach in their assessment and categorize them accordingly. From 26 June the new requirements come to effect. In summary, a CIF must adjust their policies and procedures to:

• obtain sufficient information regarding origin of funds and ultimate beneficiary owners
• maintain the information updated on frequent basis
• use the information obtained to categorize client based on risk for AM/TF
• monitor and perform due-diligence on clients based on their risk classification