Customer Due Diligence (CDD/KYC) under ACIP
AML/CTF rules require accountants to systematically identify and verify customer identities before delivering designated services to block money laundering and terrorism financing.
This involves collecting basic information like name, address, DOB, and contact details via reliable IDs (passport, driver’s license), cross-verifying against official sources or certified copies for individual customers and extending to beneficial owners with 25%+ control in companies/trusts. You should always remember "Rule of 2"
A risk-based approach should be applied where enhanced CDD for PEPs/high-risk countries/complex setups, and simplified CDD for low-risk retail clients.
Enhanced Customer Due Diligence (ECDD) include Screening high risk customers (or beneficial owners) against PEP lists and sanction list online using TrustEasy/TrustSoft wherever necessary. Source may include following international watch list : The Accuity OFAC list, The Argentinean List, The AUSTRAC List , Austrian Central Bank, The Bank of England List, Bank of Italy Unauthorized Banking or Financial Activity List, The Belgian List, Bureau of Industry & Security (formerly the BXA List or Denied Persons List), Bureau of International Security and Nonproliferation, Canadian Economic UN Sanctions, Canadian Economic Sanctioned Countries, Central Bank of The Bahamas, Central Bank of Ireland Warning Notices, Central Bank of Seychelles Offshore Banks List, Central Bank of Seychelles Terrorists List, Central Bureau of Investigation India, Chinese Ministry, Cumulative Warning List, Defense Trade Controls List of Debarred Parties, Dutch Bank List (De Nederlandsche Bank), European Union List, FBI List The Financial Action Task Force List, France list of entities requiring freezing of funds, German Federal Bank List (Deutsche Bundesbank), Government of Canada List (OSFI List), The Government Officials List, Hong Kong Monetary Authority List, Indian Ministry: list of terrorist organisations under the unlawful activities (prevention) act 1967, International Arms Traffickers, Interpol Wanted Fugitives, Israeli Ministry of Defense Terror List, Japan Ministry of Finance for financial sanction list, Luxembourg Commission of Monitoring of the Financial Sector Investor Warnings, Mauritius - Financial Services Commission License Revocations, Mexican Administrative Sanctions List, Monetary Authority of Singapore List, OCC Unauthorized Banks, Saudi Arabia Militants, Section 311 List, South African Police Service Wanted List, Spain List of entities requiring freezing of funds, Swiss SECO Sanctions List, Taiwan Bureau of Monetary Affairs Sanctions List, Tax Haven List, Terrorist Exclusion List not allowed to enter the US, UK Home Office List of terrorist organisations, The United Nations List requiring freezing of funds, The United Nations Travel Restrictions List, US Government Officials List, US Marshals List of most wanted fugitives from the U.S. Marshals, World Bank Debarred List
For simplified CDD, TrustEasy allows for digital checks against government databases (ASIC, ATO, DVS, GovID, MyID etc), bureau service provider, public records and other verifiable data.