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Guideline on Anti-Money Laundering and the Combating of Terrorist FinancingPolicies and procedures should address non face-to-face transactions which have aninherent risk of forgery and fraud. Financial institutions should conduct a riskassessment to identify the types and levels of risk associated with their telephone andInternet banking applications and, wherever appropriate, they should implement multifactorverification measures, layered security, or other controls reasonably calculated tomitigate those risks. The level of verification used should be appropriate to the risksassociated with the particular product or service.Additionally, institutions should proactively assess various risks posed by emergingtechnologies and design customer identification procedures with due regard to suchrisks. To assist in the identification and verification of non-face-to-face customers,financial institutions should:a) Ensure that documents presented are certified by the relevant and appropriateauthority;b) Require customers to submit additional documents to complement those which arerequired for face-to-face customers to verify identity;c) Make face to face contact with the customer;d) Require the first payment be made through a financial institution which has similarcustomer due diligence standards;e) Make independent contact with the customer, for example by telephone on a listedbusiness or other number;f) Carry out employment checks (where applicable) with the customer’s consentthrough a job letter; andg) Obtain any other information if deemed appropriate.Where initial checks fail to identify the customer, additional checks should beindependently confirmed and recorded. If the prospective customer is required to attenda branch to conduct the first transaction, or to collect account documentation orcredit/debit cards, then valid photo bearing identification should be obtained at that time.12.3.2. (vi.) Introduced businessA financial institution may rely on other regulated third parties 20 to introduce newbusiness in whole or in part. Nevertheless, the ultimate responsibility remains with the20 In practice, this reliance on third parties often occurs through introductions made by another member of the same financial services group orin some cases from another financial institution. It may also occur in business relationships between insurance companies and insuranceagents / brokers.Page 25 of 75
Guideline on Anti-Money Laundering and the Combating of Terrorist Financingfinancial institution for customer identification and verification that the documentaryevidence of the introducer that is being relied upon, is satisfactory for these purposes.Financial institutions should therefore:a) Document in a written agreement the respective responsibilities of the two parties;b) Satisfy itself that the regulated entity or introducer has in place KYC/ CDD practicesat least equivalent to those required by Trinidad and Tobago law and the financialinstitution;c) Obtain copies of the due diligence documentation provided to the introducer withina reasonable time frame subsequent to the commencement of the businessrelationship; andd) Consider terminating the relationship with an introducer who is not within thefinancial institution’s group, where there are persistent deviations from the writtenagreement and where an introducer fails to provide the requisite customeridentification and verification documents.A foreign financial institution may act as an introducer if:a) It is an entity regulated by a regulatory or supervisory body equivalent to theCentral Bank or the TTSEC;b) It is based in a country subject to equivalent or higher AML/ CTF standards ofregulation; andc) There are no obstacles which would prevent the financial institution from obtainingthe original documentation.Reliance on an eligible introducer should be approved by senior management and thedecision as to whether normal due diligence procedures are followed should be part ofthe financial institution’s risk-based assessment.Notwithstanding any reliance on an eligible introducer’s KYC/ CDD procedures, financialinstitutions should ensure that they immediately obtain all the relevant informationpertaining to a customer’s identity. Financial institutions should have clear and legiblecopies of all documentation in their possession within 30 days of receipt of the writtenconfirmation of the eligible introducer that they have verified customer identity inaccordance with their national laws. The eligible introducer must certify that anyphotocopies forwarded are identical with the corresponding originals. This certificationshould be provided by a senior member of the introducer’s management team. Ifdocuments are not obtained within 30 days of receipt of the introducer’s writtenconfirmation, the account should be suspended and if after a further reasonable period,Page 26 of 75
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