MAS Updates
MAS Notice 3001
4 CUSTOMER DUE DILIGENCE
When CDD Measures are to be Performed
4.1 A licensee shall perform CDD measures in accordance with this Notice when -
(a) the licensee undertakes a relevant business transaction for any customer;
(b) there is a suspicion of money laundering or terrorist financing, Not withstanding that the licensee would otherwise not be required by this Notice to perform CDD measures; or
(c) the licensee has doubts about the veracity or adequacy of any information previously obtained.
CDD Measures where Relevant Business Transactions are Established
(I) Identification of Customers
4.2 A licensee shall identify each customer for whom the licensee undertakes a relevant business transaction.
4.3 Where a licensee suspects that two or more relevant business transactions are or may be related, linked or the result of a deliberate restructuring of an otherwise single relevant business transaction into smaller transactions in order to evade the thresholds provided for in this Notice, the licensee shall aggregate them and treat them as a single relevant business transaction for the purposes of this Notice.
