Client Newsletter

Ongoing Client Due Diligence

Ongoing Client Due Diligence (OCDD) has been receiving a bit of press coverage lately and has been highlighted by the Financial Markets Authority (FMA) as an obligation that all financial institutions need to be undertaking. This is often referred to in the same breath as Anti-Money Laundering and Countering Financing of Terrorism Act 2009 (AML/CFT Act).

In a recent FMA Report, they commented that Customer Due Diligence CDD, Enhanced CDD and Ongoing CDD remain problematic for "reporting entities". They also noted a number of deficiencies, and AML and CFT programmes and reporting entities (RE's) were not undertaking ECDD and OCDD when required and their "account monitoring systems were not fit for purpose".

As a solution for RE's (financial institutions) OCDD obligations, we are working with both Centrix and Equifax to provide a service that clients can use periodically to validate their current client information. Such a service is likely to be based on a supplied file format that the Bureau will run through their data and return either validated client information or an exception report. These exceptions include validation of address, alerts to additional information that has been added to the file such as AKA's, deceased individual flags, lost or stolen ID's, credit suppression flags etc. As these services evolve we will keep you posted as to processes, costs and time frames.