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Case study

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.

  • Case Study
  • Sector
  • Service
    Criminal Finances
  • Service
    Money Laundering and Criminal Finances Legislation Compliance

Contact details

Phone: 0121 796 4020


Fax: 0843 216 4240


Tenet Compliance & Litigation Limited
Sterling House, 71 Francis Road, Edgbaston, Birmingham B16 8SP


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Tenet Compliance & Litigation Limited. Registered Office, Sterling House, 71 Francis Road, Edgbaston, Birmingham B16 8SP. Registered in England and Wales. Registered No: 09776405. Authorised and regulated by the Solicitors Regulation Authority. SRA Identification No. 626562.

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