When should verification of the beneficiaries of a legal arrangement be undertaken?

The AMLTF Code of Practice allows different timelines for the identification and verification of beneficiaries. Refer to FAQ on When CDD should be undertaken for the beneficiaries of a trust or life insurance policy, and note that section 23 (2Ba) of the AMLTF Code of Practice permits verification of beneficiaries after the business relationship has been established, if it takes place:

• at or before payout; or
• at or before the time the beneficiary exercises a vested right under the legal arrangement.   

Consequently, only beneficiaries who have a vested right to a legal arrangement must be verified.