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Internal policies, procedures and controls in respect of money laundering, proliferation financing and terrorism financing

Corporate Service Providers Regulations 2025

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—(1) A registered corporate service provider (X) must develop, implement and maintain adequate internal policies, procedures and controls to prevent money laundering, proliferation financing and terrorism financing relating to the following matters:(a)CDD measures (including simplified and enhanced CDD measures) and ongoing monitoring (including enhanced ongoing monitoring);(b)reporting;(c)record‑keeping;(d)risk assessment and management;(e)audit of the internal policies, procedures and controls;(f)the monitoring and management of compliance with, and the internal communication of, the internal policies, procedures and controls;(g)hiring and training of employees;(h)customer screening.(2) The internal policies, procedures and controls mentioned in paragraph (1) include internal policies, procedures and controls —(a)which provide for the identification and scrutiny of —(i)complex or unusually large transactions;(ii)unusual patterns of transactions which have no apparent economic or visible lawful purpose; and(iii)any other activity which X regards as particularly likely by its nature to be related to money laundering, proliferation financing or terrorism financing;(b)which specify the taking of additional measures, where appropriate, to mitigate the risk of —(i)the development of new products and new business practices, including new delivery mechanisms, for money laundering, proliferation financing and terrorism financing; and(ii)the use of new or developing technologies, for both new and pre‑existing products, for money laundering, proliferation financing and terrorism financing; and(c)to determine whether any customer or any agent or beneficial owner of a customer is a politically‑exposed person.(3) X must, in deciding what the adequate internal policies, procedures and controls mentioned in paragraph (1) are, take into consideration the following:(a)any risk of money laundering, proliferation financing and terrorism financing;(b)the size of X’s business.

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