Illustrative Customer Due Diligence Templates Page 19
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25EP 200 IG 2
Section 3: Client Meeting
Question
Response
Client relationship is established through a non-face-to-face approach.
Yes
No
Yes
No
Client relationship is established through online, postal or telephone, where
non face to face approach is used.
Yes
No
Client relationship is not established through referral.
6
(where applicable)
Higher
Low
Client relationship is established through referral by a member firm in a
risk/not in a
jurisdiction that is: ________________________________.
low risk
country
Yes
No
The member firm does not have equivalent AML/CFT measures that are able
to mitigate the risks of being from a higher risk country.
*CDD documents must be obtained from the member firm
“Yes” to any of the questions in Sections 1, 2 and 3 serves as an indicator of higher risk. Where there is
one or more “yes” responses, professional judgment, with reference to the policies and procedures of the
professional firm, must be exercised as to the nature of the Customer Due Diligence to be carried out.
Please discuss any risk factor with the Money Laundering Reporting Officer (MLRO).
The following is only where the client is, or is associated with, a PEP.
PEP risk factors:
Expected receipt of large sums from governmental bodies or state-owned entities
Source of wealth described as commission earned on government contracts
Request to associate any form of secrecy with a transaction
Use of accounts at a government-owned bank or government account as source of funds
None of the above
Other (please specify):
19
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