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Existing clients / partners (KY in place) |
3rd party without KY |
PEP (Politically Exposed Persons) |
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KY to be performed by JM’s? |
NO Records in place with Onboarding or Procurement
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YES Vigilance and DJAAMS* |
YES Vigilance and DJAAMS* |
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Do I need Manager pre-approval? |
YES if.. The invitation value is £125 or above but below £420.
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YES if.. Invitation value is £125 or above but below £420 |
N/A |
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Do I need Manager & Compliance pre-approval? |
YES if.. The gift value is £125 or above and/or the Invitation value is £420 or above.
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YES if.. The gift value is £125 or above and/or the Invitation value £420 or above. |
YES For any Gift/Invitation value |
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Note: *The evidence documenting the check must be kept by the JMs if below £125 and attached to the dedicated register if the value is at/above £125.
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