The one where
a bank wanted to know when to apply enhanced due diligence on customers

Advice on the application of Regulation 33 of the Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017 (“MLRs”)

The client, a Fintech deposit taking bank, required detailed advice on highly specific points regarding Reg.33 of the MLRs, namely:

1. in relation to Reg.33(1)(b), in circumstances where CDD is already applied at a relationship level, when exactly EDD is required; and
2. in relation to Reg.33(6), clarification on the factors to be considered when assessing whether there is a higher risk of money laundering and terrorist financing.

The advice was required urgently, and Tenet was able to deliver both timely and practical advice to ensure that the client carried out its obligations under the MLRs accurately.