CDD FAQ - Enhanced CDD AMLHub Frequently Asked Questions

For Enhanced CDD, you must, in addition to Standard CDD, obtain the following:

1. information relating to the source of the funds or the wealth of the client; and
2. any additional information prescribed by regulations.

It is important that you include a narration/story of the client’s source of funds/wealth. You must also, according to the level of risk involved, take reasonable steps to verify this information.

Source of wealth relates to how those funds arrived there in the first place e.g. how your client obtained the money. You need to understand and include information on a client’s wider wealth, but you only need to verify this information as far as the transaction itself is concerned. It is important that you consider and ensure the information you gather aligns with the transaction.

Source of funds relates to where the funds have actually come from e.g. a New Zealand bank account in the client’s name.

The level of verification is based on the client’s risk. To help you verify information about the client’s source of wealth or funds, you may use publicly available information on the internet, other commercially available databases or documents issued by third parties that support their financial position.

You will need to refer to your AML/CFT Compliance Programme for more details.

You will need to refer to your AML/CFT Compliance Programme for more details.

The following client types are deemed to be higher risk:

1. trusts or another vehicle for holding personal assets;
2. PEPs
3. a non-resident client from a country that has insufficient anti-money laundering and countering financing of terrorism systems or measures in place
4. a company with nominee shareholders or shares in bearer form.

Your client’s source of wealth is the origin of their entire body of assets. This information provides an indication of the amount of wealth your customer would be expected to have, and a picture of how they acquired it.

Your customer's source of funds is narrower. It is the origin of funds used for the transactions or activities that occur within the business relationship with you.