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HMRC internal manual

International Exchange of Information Manual

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HM Revenue & Customs
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Due Diligence: Pre-Existing Individual Accounts: Higher Value Accounts: Relationship Manager Inquiry

Due Diligence: Pre-Existing Individual Accounts: Higher Value Accounts: Relationship Manager Inquiry

The relationship manager enquiry is required for high value individual accounts in addition to the electronic search [see IEIM402920] and the paper record search [see IEIM402940]. The Financial Institution must consider whether any relationship manager associated with an account, which includes any accounts aggregated [see IEIM403560] with such an account, has knowledge that would identify the Account Holder as a Reportable Person.

A relationship manager is an employee or officer of the Financial Institution who has been assigned responsibility for specific Account Holders on an ongoing basis. A relationship manager will provide advice to Account Holders regarding their accounts as well as recommending and arranging for the provision of financial products, services and other related assistance.

Relationship management must be more than ancillary or incidental to a person’s job role. Thus a person with some contact with Account Holders, but whose functions are of a back office, administrative or clerical nature, is not considered to be a relationship manager.

The relationship manager also has an important role in identifying any change of circumstance [see IEIM403020] in relation to a high value individual account. A Financial Institution must ensure that it has procedures in place to capture changes that are made known to the relationship manager in respect of the Account Holder’s reportable status.