Enhanced Due Diligence Policy (VML003)

1. INTRODUCTION

Under the Money Laundering (Jersey) Order 2008 (MLO), enhanced due diligence procedures should be applied when a relationship or transaction is assessed as presenting a higher than standard/low risk rating.

2. PROCEDURE

Following the completion of the Risk Assessment, should the client present at any time during the course of business as being higher than standard risk, we must perform the appropriate enhanced due diligence and complete form ID1C. Copies of this together with supporting evidence must be sent to the Head of Risk and Compliance for review with a copy being held on the client file. The matter may also need to be referred to the Risk Committee. You must also ensure that prior approval from the MLRO or partner is
sought where necessary and evidenced on the form.

NB. If a client presents as a Politically Exposed Person (PEP), they must always be treated as high risk. A PEP is defined within the Viberts AML Handbook section 5.16.

3. ENHANCED DUE DILIGENCE MEASURES INCLUDE: 

3.1. Obtaining further CDD such as ID, source of funds and source of wealth from either the client or independent sources such as the internet and public and commercially available databases such as:

• Public registries.
• Telephone directories.
• Bank statements.
• Credit reference agency checks.

3.2. Obtaining further verification of ID from a regulated company or registered professional such as a GP, bank manager or public official.

3.3. The Risk Committee or Head of Risk And Compliance may require additional research be undertaken including obtaining an enhanced due diligence report.

3.4. If the client is a personal asset holding vehicle we should understand the structure, purpose and rationale and be satisfied the use of vehicle is for genuine and legitimate purposes.

3.5. If the client is a company with nominee shareholders we should ensure these are being used for good and legitimate reasons. If the client is administered by a regulated trust and company services provider within Jersey, Guernsey and the Isle of Man, and the nominee is that of the provider, in the absence of other higher risk factors, we would not consider the client represents higher risk.

3.6. Seeking partner and MLRO approval before establishing any new business relationship.

3.7. Ongoing monitoring of client activity conducted by fee earner using the ID1D form.

3.8. Online C6 Intelligence search to determine whether the client is on any high alert listings for money laundering, terrorist and sanctioned entities listing.

3.9. More frequent reviewing of client relationships can be requested to be to be carried out by the compliance function or other employees not directly involved in managing the client relationship.

3.10. Closer monitoring of any monetary transactions connected with the client relationship ensuring the first payment is paid through an account opened in the client’s name with a regulated institution.