DELAYED CDD under new AML/CTF rules : S6.(12-15) & S6.-32
When exactly should CDD be conducted? Can it be delayed?
Delayed CDD is allowed if both of the below conditions are met:
1. It is essential to delay CDD to avoid interrupting the ordinary course of business, and
2. There is low additional ML/TF/PF risk if CDD is delayed.Even then, RE must collect all required information and verify it “as soon as reasonably practicable” and always within strict timeframes specified under the rules.
Delayed CDD is allowed if both of the below conditions are met:
1. It is essential to delay CDD to avoid interrupting the ordinary course of business, and
2. There is low additional ML/TF/PF risk if CDD is delayed.Even then, RE must collect all required information and verify it “as soon as reasonably practicable” and always within strict timeframes specified under the rules.