Customer Due Diligence - Requirements & Best Practice

Customer due diligence (CDD) is a fundamental component of an effective AML/CFT Compliance Programme. As regulatory expectations increase it becomes ever more important to fully understand the salient legislative provisions and be in a position to develop practical and effective measures on a risk-sensitive basis.

With this in mind, this two-part course has been designed to outline the regulatory requirements and expectations, as well as to detail good practice and offer workable solutions.

The first session will introduce the key concepts, and cover the following core elements:

• Identification and verification procedures for customers, beneficial owners and other related parties;
• Understanding the nature and purpose of business relationships to develop customer risk profiles; and
• Conducting ongoing monitoring for reporting suspicious transactions and maintaining and updating customer information.

The second session will provide guidance on how to complete a Customer Risk Assessment (CRA) and on the application of a commensurate level of CDD, including both Simplified Due Diligence (SDD) and Enhanced Due Diligence (EDD) measures.

Specific areas that will be subjected to greater attention include the following:

• Beneficial Ownership;
• Introducers, intermediaries and agents;
• Politically Exposed Persons;
• Non-Reputable and High-Risk Jurisdictions;
• Source of wealth and source of funds; and
• Reliance and Outsourcing.

The presentations will outline regulatory requirements and best practices, offer practical solutions, and address a number of frequently asked questions.

The Speaker

Antonio Ghirlando is a seasoned compliance specialist with a specific focus on financial crime compliance, including the prevention of money laundering, countering the funding of terrorism, combatting proliferation finance, sanctions, anti-bribery & corruption, and fraud. He is also well versed in other regulatory compliance obligations.

Antonio is actively involved in the provision of real-time operational support, specialist advice, intuitive guidance and training to several businesses seeking to ensure ongoing compliance with their regulatory obligations. He also assists Money Laundering Reporting Officers (MLROs) and Compliance Officers with their day-to-day tasks and oversight.

During his career he has worked with various licensed entities in both the financial and non-financial sectors, having served as the Head of Compliance, Head of Financial Crime Compliance, Money Laundering Reporting Officer (MLRO) and Data Protection Officer (DPO). He also headed the Compliance and Legal & International Sections of the Financial Intelligence Analysis Unit (FIAU) and served as the Secretary General of the Malta Bankers’ Association (MBA).

Antonio has been involved in several local and international committees, and has also presented numerous papers at various workshops, seminars, conferences and training events. Antonio is a graduate of the University of the Witwatersrand in Johannesburg, South Africa.

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