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JFSC Themed Examination Programme 2016/17: Enhanced & Simplified Due Diligence Summary Findings Issued: August 2017

This paper provides an overview of findings from the JFSC’s themed programme of on-site examinations on the subject of Enhanced and Simplified Due Diligence, which were conducted by the JFSC in 2016 and 2017. This comprised of two phases; the first spanned eight banks between September and December 2016, whilst the second covered six Trust Company Businesses and one Money Service Business between January and April 2017. The JFSC’s observations in this report are drawn from its findings from those examinations. THE Prime observations in the reports are shown as follows
1. Banks…………………….
a. Group influence………..
b. Group support……………
c. PEPs………………………….
d. Account operation……..
e. Account opening……….
f. Control environment….
2. TCBs & MSB……………
a. Records…………………….
b. Intermediaries…………..
c. Compliance monitoring
d. Operations………………..
e. Conflicts……………………
f. PEPs………………………….
g. Other

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