When should CDD be undertaken for the beneficiaries of a trust or life insurance policy?

In accordance with section 19 (4A) of the AMLTF Code of Practice, CDD must be performed:

• as soon as the beneficiary is identified as a specifically named natural person, legal person, or legal arrangement, by recording the name of the beneficiary; and
• as soon as the beneficiary is designated by characteristics or by class, by obtaining sufficient information about the beneficiary so that the FI would be able to identify the beneficiary at the time of payout.