What the document covers
The bulletin links customer identification to detecting and reporting suspicious activity. It discusses professional AML obligations under the framework then in force.
Specific requirements and implications
The illustrative form can be signed by the person providing the information; the bulletin does not demand signatures from every director or beneficial owner. Screening extends beyond sanctions to relevant adverse information, with results and the reasoning for clearing alerts retained. The form should be adapted to the engagement and does not replace applicable obligations. The bulletin also directs audit firms to use SONAR for suspicious transaction reports, separating due-diligence records from the reporting channel.
Official source
A concise, independent Apex Gateway guide based on the official English source, not a reproduction of the complete document. Consult the original for full conditions, exceptions and subsequent updates.
Read the official PDF ↗