An existing customer is someone who was in a business relationship with your reporting entity immediately before the AML/CFT Act began applying to the reporting entity.
The AML/CFT Act requires you to conduct CDD on an existing customer if there has been a “material change” in the nature or purpose of the business relationship, and you determine that you have “insufficient information” about that customer. The Department considers that “insufficient information” means that CDD has not been conducted to the level required by the AML/CFT Act.
You must also conduct ongoing CDD on an existing customer. This requires you to ensure that the business relationship, including the activities and transactions within it, are consistent with your knowledge about the customer, their business and risk profile. When doing this, you must regularly review any information you hold about the existing customer.
The requirement to conduct ongoing CDD and account monitoring on an existing customer may require you to update your CDD records even in the absence of a “material change” in the business relationship.
You must also conduct ongoing CDD on an existing customer. This requires you to ensure that the business relationship, including the activities and transactions within it, are consistent with your knowledge about the customer, their business and risk profile. When doing this, you must regularly review any information you hold about the existing customer.
The requirement to conduct ongoing CDD and account monitoring on an existing customer may require you to update your CDD records even in the absence of a “material change” in the business relationship.
Material change
‘Material change’ is not defined in the AML/CFT Act. However, the supervisors’ AML/CFT Programme Guidance adopts a working definition of “an event, activity or situation that you identify that could change the level of ML/TF risk you may encounter”: AML/CFT Programme Guidance (PDF, 168KB)
‘Material change’ is not defined in the AML/CFT Act. However, the supervisors’ AML/CFT Programme Guidance adopts a working definition of “an event, activity or situation that you identify that could change the level of ML/TF risk you may encounter”: AML/CFT Programme Guidance (PDF, 168KB)