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Administrative FSP – Who is responsible for Customer Due Diligence?

The Financial Intelligence Centre Act 2002, as amended (FIC Act) places an obligation on all accountable institutions (AIs) to perform CDD on prospective clients entering into a single transaction with the AI, or with whom a business relationship is established. In terms of section 21A of the FIC Act, an AI may not conclude a single transaction or establish a business relationship with an anonymous client.

Questions surrounding customer due diligence (CDD) have always been prevalent when dealing with instructions from another party. Where the contact with the underlying client of the instructing party is also limited, answers to these questions become even more uncertain.

Another question that needs to be answered is, who is the client? In an insightful article, Carolee Reyneke Minnaar, Compliance Researcher and Developer at Moonstone Compliance provides answers to all these questions.

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