4.46

Version date: 1 March 2021 - onwards

Directive (EU) 2015/849 lists specific cases that firms must always treat as higher risk:

a) where the customer, or the customer’s beneficial owner, is a PEP (Articles 20-24);

b) where a firm enters into a correspondent relationship involving the execution of payments with a third-country institution (Article 19);

c) where a firm maintains a business relationship or carries out a transaction involving high-risk third countries (Article 18(1)); and

d) all transactions that are

i. complex;

ii. unusually large;

iii. conducted in an unusual pattern; or

iv. without obvious economic or lawful purpose (Article 18(2)).

Log in