Is CDD required for all one-off transactions?

In accordance with section 19 (4) of the AMLTF Code of Practice, CDD should be undertaken when processing one-off transactions involving:

• $15,000 or more;
• wire transfers of $1,000 or more;
• in the case of a Virtual Assets Service Provider, virtual assets of $1,000 or more; or
• $3,000 or more, or the equivalent in any other currency, for entities or professionals licensed or registered under the Virgin Islands Gaming and Betting Control Act, No. 14 of 2020.

The above thresholds include multiple transactions for smaller amounts that appear to be linked and should consider the specific risks presented. However, FIs and DNFBPs may establish lower thresholds than the ones specified.
In addition, CDD should be undertaken when:

• the transaction presents a higher risk scenario;
• there is doubt about the veracity or adequacy of previously obtained CDD information; and
• where there is a suspicion of ML, TF or PF, irrespective of any threshold.