Learn about the key aspects of our Ongoing CDD practices and understand why we're reaching out to collect more information relating to your investing entity.
Background
Ongoing CDD is a process that financial institutions and regulated entities undertake to continuously monitor their customers throughout the duration of the business relationship. It is an essential component and a requirement of the Anti-Money Laundering and Countering Financing of Terrorism Act 2009 (AML/CFT Act).
Key Aspects of Ongoing CDD
As a regulated financial institution, Icehouse Ventures is required to undertake ongoing CDD measures when:
- There has been a material change in the business relationship with the customer, and/or
- We have insufficient information about a customer, and/or
- We have set a review period for the customer.
Ongoing CDD may be triggered by any of the following:
- Regulation/Guidance change: over time, the regulations and guidance which financial institutions are expected to follow change. As the requirements to collect customer information change, Icehouse Ventures may need to periodically remediate our existing customer data.
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Monitoring Transactions: we employ a set of systems and procedures to monitor customer transactions for any deviations from normal behaviour. Unusual or high-risk transactions trigger further investigations.
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Risk Profiling: we assess the risk profile of our customers based on factors such as the geographical location, industry, transaction volumes, and the nature of their business activities.
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Enhanced Due Diligence (EDD): in certain cases, when dealing with more complex customers, ongoing CDD may involve implementing enhanced due diligence measures. This can include collecting additional information, conducting more frequent reviews, and obtaining updated documentation to ensure continued compliance with regulatory requirements.
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Customer Information Updates: we regularly request updated customer information to ensure the accuracy and completeness of our records. This includes verifying and validating customer identification, contact details, and other relevant information.
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Screening: ongoing CDD involves regular screening of customers against various watchlists, sanction lists, politically exposed persons (PEP) lists, and other relevant databases to identify any potential connections to illegal activities or prohibited individuals/entities.
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Reporting Suspicious Activities: if during the ongoing monitoring process, we identify any suspicious or potentially illicit activities, we are obligated to report such activities to the Financial Markets Authority, which is our governing body.
Why have you been asked to provide further information?
Based on the key aspects of ongoing CDD listed above, we may have come across a situation where we noticed the CDD information we had previously collected for your investing entity was either inaccurate, outdated or missing altogether. To ensure the accuracy and completeness of our records and to comply with AML/CFT requirements, we are now reaching out to remediate/update this information.
For more information on the specific documentation we've requested from you, please read our help desk article "What is Customer Due Diligence (CDD) and what do I need to supply to comply with regulation?"
If you have any questions, please don't hesitate to reach out to our Operations Team - we'd be happy to help : )