Sunday, April 21, 2019

ENHANCED DUE DILIGENCE IS NOW THE ORDER OF THE DAY ON ALL TRANSACTIONS EVEN REMOTELY RELATED TO HIGH-RISK JURISDICTIONS



As you can see below, from the HM Treasury Advisory on money laundering and terrorist financing countermeasures and monitoring required for high-risk countries, enhanced due diligence is required for all Iranian transactions. It is humbly suggested that you apply this wisdom regarding enhanced due diligence above and beyond what is required, meaning only Iran and the DPRK. Smart compliance officers are now employing enhanced due diligence measures on ALL countries that have ever been on the FATF list, are known source countries for narcotics, or are known to allow, or facilitate, terrorist financing.

Consider ordinary due diligence to be obsolete for any queries other than low-risk jurisdictions.





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