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.