The relationship manager enquiry is required for high-value individual accounts in addition to the electronic search and the paper record search. The financial institution must consider whether any relationship manager associated with an account, which includes any accounts aggregated with such an account, has actual knowledge that would identify the Account Holder as a Reportable Person.
A relationship manager is an employee or officer of the financial institution who has been assigned responsibility for specific Account Holders on an on-going basis. A relationship manager will provide advice to Account Holders regarding their accounts as well as recommending and arranging for the provision of financial products, services and other related assistance.
Relationship management must be more than ancillary or incidental to a person’s job role. Thus a person with some contact with Account Holders, but whose functions are administrative or clerical nature, is not considered to be a relationship manager.
The relationship manager also has an important role in identifying any change of circumstance concerning a high-value individual account. A financial institution must ensure that it has procedures in place to capture changes that are made known to the relationship manager in respect of the Account Holder’s reportable status.