Customer due diligence outsourced: is it legal and what one should pay attention to?

September 28, 2021

Nowadays, any entrepreneur registered in Latvia running a business or offering professional services subject to AML/CTPF law is well aware of the scope of certain and mandatory actions that must be followed before providing a service or during the business relationships. 

The extent of the customer’s due diligence depends on a list of factors like customer’s geography, requested service and risks attributable to this customer. The most common stumbling blocks in customer due diligence for entrepreneurs subject to AML/CTPF law are:

  • improperly defined risk assessment and failure to apply suitable level of due diligence (simplified or enhanced), including determining sufficient amount of information to be obtained in the course of due diligence;
  • lack of resources, including lack of labour force, limited access to commercial databases;
  • lack of knowledge and skills to engage the applicable resources in the customer due diligence;
  • lack of skills and experience in assessment of the information being checked and determining potential risks.

For the entrepreneur to have full control of their business, the customer due diligence may be outsourced, which is also allowed by the AML/CTPF law. But before you do that, make sure that the outsourced service is performed by qualified specialists competent in AML/CTPF field. Also, one should make sure that the outsourced due diligence is in line with the approved company’s internal control system and the steps of the due diligence process are not contradicting with the provisions of the internal regulations. This condition is especially important, since in accordance with the data published by the Latvian State Revenue Service, incomplete internal control systems or absence of risk assessment procedure are the most common reasons the companies are being fined.

One of such outsource due diligence service providers is Atbilst platform. It comprises full cycle of customer due diligence, including automated checking of persons for matches in various databases (for example, PEP, list of persons of risk, sanctions lists) and automated determination of client’s risk level. To learn more about the benefits offered by Atbilst platform here: www.atbilst.lv.

As Steve Jobs said, the most precious resource we all have is time. So, let’s learn to manage our time smart, delegating tasks to those most suitable for it, thus focusing the free resources on the key goals of the business.

Alīna Gamidova


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