Refunding a Client

Yes. In circumstances where a refund of a deposit is made to a buyer, you will be required to perform CDD on the buyer prior to providing the refund.

Offshore Related Issues

There is no definitive list of countries that do not have sufficient AML/CFT systems and measures in place, or are otherwise high risk.

However, some useful resources you may wish to refer to help assess the risk of judications are:

  1. Know Your Country rating table: https://www.knowyourcountry.com/country-ratings-table
  2. Basel AML Index: https://index.baselgovernance.org/
  3. Please note further detail regarding jurisdictional risk is included in your AML/CFT Risk Assessment.