Revised Central Bank-AMLA Guidelines - Anti-Money Laundering ...

AML/CFT GUIDELINEISSUED BY THECENTRAL BANK OF BARBADOSIN CONJUNCTION WITH THE ANTI-MONEY LAUNDERING AUTHORITYMAY 2011Regarding the policy framework, the licensee should therefore include a description of the types ofcustomers that are likely to pose a higher than average risk and procedures for dealing with suchapplications. High-risk customers should be approved by senior management and stringentdocumentation, verification and transaction monitoring procedures should be established.Applying a risk-based approach, enhanced due diligence for high risk accounts may include,where deemed relevant, and with more frequency than applied for low risk customers:a) An evaluation of the principals;b) A review of current financial statements;c) Verification of the source of funds;d) Verification of source of wealth;e) The conduct of reference checks;f) Checks of electronic databases;g) Review of relevant country assessment reports; andh) Periodic reporting to the Board about high risk accounts.Types of situations requiring enhanced due diligence include the below:7.4.1 Trust ClientsLicensees should take reasonable measures to obtain information about the true identity of thepersons on whose behalf an account is opened or a transaction is conducted. This appliesespecially if there are any doubts as to whether or not these clients or customers are acting ontheir own behalf.At a minimum, the licensee should obtain the following 8 : -a. Name of trust;b. Nature / type of trust;c. Country of establishment;d. Identity of the trustee(s), settlor(s), protector(s)/controller(s) or similar person holding powerto appoint or remove the trustee and where possible the names or classes of beneficiaries;e. Identity of person(s) with powers to add beneficiaries, where applicable; andf. Identity of the person providing the funds, if not the ultimate settlor.Depending on the type or nature of the trust, it may be impractical to obtain all of the above at theonset of the relationship e.g. unborn beneficiaries. In such cases, discretion should be exercisedand documented in a manner consistent with the requirements in this guideline. In allcircumstances, the licensee should verify beneficiaries before the first distribution of assets.Further, licensees should verify protectors/controllers the earlier of the first instance of exercise of8 These minimum requirements apply whether the licensee is a named trustee or is providing services to a trust.Anti-Money Laundering/Combating Terrorist Financing Guideline May 2011 16Bank Supervision DepartmentCENTRAL BANK OF BARBADOS