FORM D – Ongoing Due Diligence
(For Clients With Ongoing Business Relationships)
Section A: Client Information
Section B: Business Relationship
Section C: Risk Assessment
Section D: Ongoing Monitoring
1. Information Currency Check
Are all previously obtained client documents and information still current?
If answer is No, please provide details on the information which has changed:
2. Transaction Monitoring
Are recent transactions consistent with known client profile?
3. RES’s Recommendation
4. Estate Agent’s Review of On-Going Assessment
EAs and RESs must maintain proper documentation of all screenings and assessments done when determining whether a designated person or PEP is involved in a transaction.
All documentation must be submitted to the EA for record-keeping, to be retained by the EA for a minimum period of 5 years.
