When EDD applies

EDD must be applied where required by the Money Laundering Regulations or where the Firm assesses that a business relationship or transaction presents a high risk of money laundering or terrorist financing. The Firm may also require additional or enhanced measures where other financial crime, sanctions, proliferation financing, or reputational risks justify enhanced scrutiny, even where the statutory threshold for EDD is not met.

EDD and enhanced ongoing monitoring must be applied where:

• the Firm assesses that a business relationship or transaction presents a high risk of money laundering or terrorist financing, including where the Client and Matter Risk Assessment identifies the matter as Higher Risk for money laundering or terrorist financing purposes;
• the client is established in a FATF Call for Action country, or a relevant transaction involves a party established in such a country, in circumstances falling within Regulation 33;
• the PEP provisions in Regulations 33 and 35 apply, including where the client or beneficial owner is identified as a politically exposed person ("PEP"), a family member of a PEP, or a known close associate of a PEP;
• the client has provided false or stolen identification documentation or information and the Firm proposes to continue to deal with the client;
• a transaction is unusually complex or unusually large, given the nature of the transaction;
• there is an unusual pattern of transactions;
• the transaction or transactions have no apparent economic or legal purpose;
• the circumstances otherwise constitute a case which, by its nature, can present a higher risk of money laundering or terrorist financing;
• another applicable provision of the Money Laundering Regulations requires EDD; or
• the MLRO or MLCO otherwise determines that additional or enhanced measures are required.