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HMRC internal manual

Anti-money laundering guidance for supervised businesses

AMLG11410 - Guidance for all sectors: Reliance

14.10 Reliance on third parties

 

Important note:

If you rely on a third party, you’ll remain responsible for any failure to apply due diligence measures appropriately.

It may not always be appropriate to rely on another person to undertake your customer due diligence checks, and you should consider reliance as a risk in itself.    

You must not rely on simplified due diligence carried out by a third party or any other exceptional form of verification.


You can rely on the following persons to apply CDD for you:

  • Another UK business subject to the Regulations.    
  • A business in the EEA who is subject to the 4th Money Laundering Directive.   
  • A branch or subsidiary established in a high country who fully complies with an EEA parent’s procedures and policies.       
  • A business in a third country who is subject to equivalent measures.   

You may not rely on a business established in a country that has been identified as high risk by the Financial Action Task Force or by HMRC.

If relying on a third party to carry out CDD measures, you must: 

  • Immediately obtain from the third party all the information needed to identify and verify the customer, beneficial owners or any person purporting to act on behalf of the customer as well as the purpose and intended nature of the business relationship or occasional transaction.
  • Enter into arrangements with the third party being relied on which:
    • Enable you to obtain from the third party immediately on request copies of any identification and verification data and any other relevant documentation on the identity of the customer or beneficial owner; and
    • Require the third party to retain copies of the data and documents referred to for five years from the date on which the transaction is complete or the business relationship with the customer ends.