03.16 – Undesignated/Designated Accounts

Where a Financial Account (held by a non-financial intermediary such as a solicitor) does not meet any of the conditions in Section 3.15, but is an account, holding on a pooled basis, the funds of underlying clients of the non-financial intermediary where:

  • the only person listed or identified on the Financial Account with the Financial Institution is the non-Financial Intermediary; and
  • the non-Financial Intermediary is not required to disclose or pass their underlying client or clients’ information to the Financial Institution for AML/KYC or other regulatory requirements then, providing both conditions are met, the Financial Institution is only required to undertake the due diligence procedures in respect of the non-financial intermediary.

A designated client account is an account held with a Financial Institution, operated by a non-financial intermediary where the underlying client or clients of the intermediary are listed or can be identified by the Financial Institution. In this case the Financial Institution should, if required report the underlying client Account Holders.