05.01 – Due Diligence

The CD and Gibraltar Regulations set out that UK Financial Institutions are responsible for the identification and reporting of Financial Accounts held by Specified CD or Gibraltar Persons. These obligations are substantially the same as those for identification and reporting of Financial Accounts held by Specified US Persons, but there are differences to the indicia used to identify pre-existing individual accounts (see sections 6.3 – 6.7 of this guidance).

A Financial Institution can rely on a third party service provider to fulfil its obligations under the legislation, but the obligations remain the responsibility of the Financial Institution, and so any failure will be seen as a failure on the part of the Financial Institution.

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