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HMRC internal manual

International Exchange of Information Manual

HM Revenue & Customs
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Due Diligence: Special Due Diligence Rules: Limits on Reason to Know

Due Diligence: Special Due Diligence Rules: Limits on Reason to Know

Pre-existing entity accounts

For the purposes of determining whether a Financial Institution that maintains a pre-existing entity account has reason to know that the status applied to the entity is unreliable or incorrect, the Financial Institution is only required to review information that may contradict the status claimed if such information is contained in:

  • the most recent self-certification and documentary evidence;
  • the current customer master file;
  • the most recent account opening contract; and
  • the most recent documentation obtained for AML/KYC procedures or for other regulatory purposes.

Multiple accounts

A Financial Institution that maintains multiple accounts for a single Account Holder will have reason to know that a claimed status for the person is inaccurate based on account information for another account held by the person only to the extent that the accounts are either required to be aggregated or because of any other ‘reason to know’; for example, knowledge of a relationship manager.

Change of address within same jurisdiction

A change of address in the same jurisdiction as that of the previous address is not a reason to know that the self-certification or documentary evidence provided is inaccurate.

Conflicting indicia

A Financial Institution does not know or have reason to know that a self-certification or documentary evidence is unreliable or incorrect solely because it discovers any of the following indicia and such indicia conflicts with the self-certification or documentary evidence:

  • one or more telephone numbers in a Reportable Jurisdiction and no telephone number in the jurisdiction of the Reporting Financial Institution; or
  • standing instructions (other than with respect to a Depository Account in the case of the CRS/DAC) to transfer funds to an account maintained in a Reportable Jurisdiction; or
  • currently effective power of attorney or signatory authority granted to a person with an address in a Reportable Jurisdiction.


Special Due Diligence Rules: Limits on Reasons to Know
  1. IEIM403520
    Special Due Diligence Rules: Limits on Reason to Know: Examples